Privacy Policy

Planet First Partners Gérant Sàrl, with offices 9B Boulevard du Prince Henri, register with the Trade and Companies under number B250999 (collectively “Company”, “we”, “us”, “our”) are committed to safeguarding the personal data it processes in connection with its business in accordance with fair information practices and applicable data protection legislation.

Please note that this Privacy Notice must be read in conjunction with our Website User Disclaimer and Cookie Policy.

1. Scope
This notice (“Privacy Notice”) explains how the Company, in its capacity as data controller, treats the personal data of its business contacts as well as services providers, agents, consultants, and website visitors (“you”, “your”), in the framework of its activities.

2. How We Collect Personal Data
We collect your personal data :

at the occasion of business events, meetings, networking events or similar occurrences, regardless of whether they occur in our offices or at an external location, including, as the case may be, through CCTV or other access systems;
while conducting public searches on professional or social-media databases;
which is publicly disclosed;
when you visit our website (please refer to our Cookie Policy for more information ).

3. Type of Personal Data We Collect
In the normal course of our activities, we collect the following types of personal data:

Contact information, such as your name, home and professional address, email address, date of birth, gender, phone number and images taken by CCTV or access systems;
Due diligence information in connection with an actual or prospective corporate transaction or investment, including information about your employer, your own company, your business and your contacts;
Relationship information that helps us do business with you and contact preferences;
Compliance and risk management information, such as information for fraud prevention;
Upon visiting our website: IP address, information about your operating system, internet server provider and software, the pages accessed within our Website, the link that laid to our Website, geolocation information, etc.

4. Use of Your Personal Data
We collect your personal data for the purpose of current or future business relationships with you and more preciselyfor the purposes specified below.
We use your personal data for the following purposes:

Fulfilling our legal obligations;
Managing your ongoing relationship with us, including communicating with you;
Providing and improving our business operations;
Legal defense and compliance, including compliance with government authority requests for information, liens, garnishments and tax compliance;
Internal reporting and auditing; and
Protection of the Company, its workforce and the public against injury, theft, legal liability, fraud, abuse, or threat to the security of our networks, communications, systems, facilities and infrastructureand for other legitimate interests.

We use the following legal bases for the processing of your personal data:

Compliance with the legal obligations to which we are subject;
The need to process your personal data for contract performance or to take steps to enter into a contract with you;
Where the processing is necessary for our legitimate business interests including notification of an investment/divestment opportunity, due diligence activities,professional advice or input in relation to an investment/divestment or with respect to one of our portfolio companies, professional advice in connection with the Company’s business or its employees,operating our business properly, protecting against fraud and other liabilities, ensuring compliance and our ability to assert legal defenses, guarantying the security and proper functioning of our networks and systems, and protecting our assets; and
Your consent, in some specific circumstances, such as conducting direct marketing.

5. Disclosures and Categories of Recipients
We have taken measures to ensure that your personal data is processed in a manner that is compatible with the purposes indicated above. For the stated purposes, your personal data may be disclosed to, or received from, the following parties:

Other Company entities, joint ventures, investee companies, subcontractors, vendors or suppliers who perform services on our behalf for the aforementioned purposes;
A newly formed or acquiring organization if the Company is involved in a merger, sale or a transfer of some or all of its business;
Certain service providers as necessary or useful to fulfill the aforementioned purposes, such as data hosting providers;
Any recipient, if we are legally required to do so, such as by court order, applicable laws or regulatory requirements; or
Any recipient when reasonably necessary such as in the event of a life-threatening emergency.

6. International Transfers
We may transfer your personal data to countries that have not been found by the European Commission to provide adequate protection. Where such transfers occur, we will ensure that adequate protection exists either through appropriate contractual arrangements or as required by law.

7. Information Security
We treat your personal data through automated and/or paper-based data processing systems and, as the case may be, CCTV. We have established routine processing functions.
We take precautions to protect personal data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We have taken appropriate technical and organizational measures to protect the information systems on which your personal data is stored, and we contractually require our suppliers and service providers to protect your personal data.

8. Your Personal Data Rights
In accordance with and subject to fulling the requirements under the applicable data protection legislation, you have the following rights:

Right of access: access your personal data detailing what personal data is being processed and for what purpose;
Right to opt out: withdraw your consent at any time where your personal data is processed with your consent;
Right of correction: update or correct your personal data so that it is accurate;
Right to be forgotten delete your personal data from our records if it is no longer needed for the purposes indicated in this notice. Once you have informed us of this request, we shall erase your personal data unless permitted by law;
Right to restrict processing: restrict the processing of your personal data in certain circumstances, such as where you have contested the accuracy of your personal data, for the period enabling us to verify its accuracy;
Right to object: object to us processing your personal data or to tell us to stop processing your personal data. Once you have informed us of this request, we shall no longer process your personal data unless permitted by law; and
Right to data portability: obtain your personal data in an electronic format and to request that we transmit this data to another data controller.

You may exercise these rights free of charge. However, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, we may refuse to act or we may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation or infringe applicable law.

9. Personal Data Retention
Your personal data will be retained as long as necessary to achieve the purposes stated in this notice, or in accordance with our legal and regulatory obligations. Our retention policies reflect applicable local statute of limitation periods and legal requirements.

10. Cookies
Please refer to our Cookie Policy for more Cookie Policy

11. How to Exercise Your Rights or File a Complaint
If you wish to exercise any of the rights awarded to you under chapter 8 above or have a question, request or complaint related to how we process your personal data, please contact usvia the communication channel of your choice:
- email: privacy@planetfirst.partners
- post: Planet First Partners Gérant Sàrl, 9B Boulevard du Prince Henri, L-1724 Luxembourg
In addition, you have the right to file a complaint with the Luxembourg data protection authority via https://cnpd.public.luor with any other relevant data protection authority.

12. Updates
We may review this Privacy Notice and update it from time to time to reflect any changes to the way in which we process personal data without obligation to inform you. We will post such changes on our website, so we invite you to regularly check this Privacy Notice for updates.
This Privacy Notice was last updated on September 14, 2020.

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