Advent International Corporation
1. About this policy
1.2 Where we refer to “personal data” in this policy, we mean any information relating to an identified or identifiable individual, including names, email addresses, phone numbers and online identifiers.
2. Who’s responsible for your personal data?
2.1 Advent International Corporation is the data controller of your personal data. This means that we determine how, and for what purposes, we use your personal data.
3. What personal data do we collect and receive?
Categories of personal data
Name and contact details – Your full name and contact details (email address, phone number, postal address, and country of residence)
When/how we get it – You might provide this information to us, including when you contact us via the contact information listed on our website
Technical information related to use of our website – Details about the browser, device and Internet connection that you use when you browse our website, technical information, including your IP address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
When/how we get it – Your device provides this information when you browse our website (whether or not you have accepted cookies)
Cookies – Our website stores small text files on your device that identify your browser. See ‘Cookies and other tracking technologies’ below for more details
When/how we get it – When you visit our website and use Advent services that require us to identify you—Cookies can also be set when you open our emails
Information about your interactions with our website – As well as the technical information above, we collect information about your visits to our websites, including the full web addresses that you access, your path of clicks, through and from our site (including date and time and whether you used a search engine), download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page
When/how we get it – When you browse our website
Due Diligence information – This may include your contact details, date of birth, ID data, details of your financial information and your proposed investment (where relevant) and various other necessary personal information.
When/how we get it – we may receive this information from a third party, for example, a law firm, who collect personal data from you and pass it on to us where we are conducting due diligence in relation to a transaction. Where this is the case, the third party is responsible for informing you that they have shared your personal data with us, directing you to this policy and obtaining any relevant consents from you to ensure you are happy with the ways in which your personal data will be used.
4. How we use your personal data and who we share it with
4.1 We use your personal data:
(a) To improve our website and make it easy to use
We may use the personal data and other information you provide in connection with your use of our website to help us improve the content and functionality of the website and to better understand our users. For example, we may use your personal data to help us understand interest in the different sections of our website.
(b) For marketing purposes
If you express an interest in relation to certain investments or our broader business activities, we may contact you to provide you with information about events or investments that we think you might be interested in.
(c) For compliance with our legal obligations
We are sometimes subject to certain legal requirements to collect, retain and disclose your personal data when officially requested to do so, for example for performing identity checks, including for anti-money laundering and ‘know your customer’ compliance, and in relation to criminal investigations.
4.2 We may share your personal data with the following recipients for the purposes listed above:
(a) Parties involved in business transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, any change in control, dissolution or similar event, personal data may be part of the transferred assets.
(b) Our affiliates
(c) Our agents, business partners, licensors and service providers
Advent, like many businesses, sometimes hires or works with other companies to perform certain business-related functions. When we employ or work with another company to perform a function of this nature, we provide them with only the information that they need to perform their specific function.
(d) Government authorities, law enforcement agencies, courts and parties to litigation
Advent may disclose your personal data if required to do so by law or in the good-faith belief that such action is necessary to: (i) comply with a legal obligation; (ii) protect and defend Advent’s rights or property; (iii) act in urgent circumstances to protect the personal safety of users of our website or the public; or (iv) protect against legal liability.
5. Direct marketing
5.1 We may contact you for marketing purposes, including to tell you more about certain events or to share news we believe you will be interested in. You’re always in control of the emails that you receive and you can update your preferences or opt out at any time by following the links in our emails or by contacting us.
6. Cookies and other tracking technologies
6.2 Most web browsers have an option that allows you to turn off all cookies or have your computer inform you each time that a request to place a cookie is being made. If you turn cookies off (or refuse to accept a request to place a cookie), you may not have access to some features on our websites and some of our services. We also might not be able to remember your preferences without using cookies.
7. International transfers of personal data
7.1 Advent is a global business, and we may transfer personal data outside the UK and the European Economic Area (EEA). Where required to do so by applicable data protection law, we use the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your personal data that is transferred outside the EEA.
8. Legal basis for our use of your personal data and legitimate interests
8.1 Legal bases – To the extent that European data protection law applies to our data processing activities, we only process your personal data where at least one of the following applies:
(a) you’ve consented to the processing of your personal data for a specific purpose – we process your sensitive personal data and send you electronic direct marketing communications based on your consent for us to do that;
(b) the processing is necessary for us to perform our contract with you (including in relation to investments or the operation of portfolio companies) or for us to take steps at your request before we enter into the contract;
(c) where we need to process your personal data to comply with a legal or regulatory obligation that we’re subject to;
(d) where we need to process your personal data to protect your vital interests (or somebody else’s); or
(e) where the processing is necessary for the purposes of our legitimate interests or a third party’s legitimate interests.
8.2 Legitimate interests – We rely on several legitimate interests for using and sharing your personal data, including:
(a) improving our services;
(b) marketing activities;
(c) identifying and pursuing new ways to develop and grow our business; and
(d) operating and administering our portfolio companies and other investments.
9. Data retention
9.1 We retain your personal data only for as long as necessary: (i) for the purposes set out in this policy; (ii) to provide our services to you; (iii) to comply with our legal obligations; or (iv) to comply with our usual business data retention policies.
10. Your rights
10.1 To the extent that European data protection law applies to our processing of your personal data:
(a) you can contact us to manage, change, limit or delete the personal data that we hold about you;
(b) you have the following rights in relation to your personal data and you can, in some circumstances, ask us to:
(i) provide you with access to the personal data that we hold about you;
(ii) correct your personal data;
(iii) erase your personal data;
(iv) restrict our processing of your personal data;
(v) object to our processing of your personal data;
(vi) object specifically to us using your personal data for profiling for direct marketing purposes; or
(vii) provide a copy of your personal data in an easily accessible format; and
(c) where you have specifically consented to our use of your personal data, you have the right to withdraw that consent at any time. Please contact us if you want to do this.
12.1 This policy applies only to this website. Our website may contain links to other sites not operated or controlled by Advent. The policies and procedures we have described here do not apply to these third party sites. The links from our website do not imply that Advent endorses or has reviewed any third party sites. We suggest contacting those sites directly for information on their privacy policies.
13. Other terms and conditions
13.1 Your access to and use of this website is subject to the Terms and Conditions of Use, available at http://www.adventinternational.com/terms-conditions.
14. Contact us and complaints
14.1 If you have any questions, comments or complaints about any aspect of this policy, or to exercise any of your rights in relation to your personal data, please contact Andrea Ramsey in Boston, +1 617 951 9400, email@example.com.
14.2 To the extent that European data protection law applies to our processing of your personal data, you have the right to make a complaint about how we process your personal data to the relevant supervisory authority.