Sanguine’s commitment to privacy
This Privacy Notice is provided by Sanguine Capital Advisors Limited (“Sanguine”, “we” and “us”), and it applies to ways in which we interact with individuals, (“Data Subjects”) in connection with our business, including, without limitation:
- directors, officers, employees and other representatives of portfolio companies in which Sanguine has made an investment or is considering making an investment;
- individual representatives of third-party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by Sanguine;
- directors, officers, employees and other representatives of Sanguine;
- individuals applying for or inquiring about and employment with us;
- individuals who consider or do invest with us and their representative agents with whom we interact during the normal course of business; and
- visitors to our websites and users of any digital services we provide.
We respect the privacy of Data Subjects. This Privacy Notice describes how we collect, use, store, process, disclose and transfer information that we may collect from Data Subjects. Please note that Sanguine may provide additional privacy notices or similar disclosures in respect of certain categories of Data Subjects (e.g., certain investors or prospective investors in a fund managed or advised by Sanguine, certain former or existing employees associated with Sanguine, etc.), and certain geographies and jurisdictions.
What data do we collect and how?
Personal Data. When we use the term “Personal Data” we mean information that can reasonably be used to identify you as an individual person. In connection with our business, we collect various types of Personal Data, including, among other things:
- identification information (e.g., name, ID card and passport numbers, nationality, place and date of birth, gender, picture, IP address);
- contact information (e.g., postal address and e-mail address, phone number);
- family situation (e.g., marital status, number of children);
- tax status (e.g., tax ID, tax residence);
- education and employment information (e.g., level of education, employment, employer’s name, remuneration);
- financial data (e.g., bank account details, credit card number, money transfers including communications on bank transfers, assets, investor profile, credit history, debts and expenses)
- other background data (e.g. information on criminal history/unlawful conduct)
We collect this Personal Data in various ways, including:
- Directly from the Data Subject (e.g., when you voluntarily submit information to the Site, or send us an email or other written correspondence)
- Indirectly from other sources (e.g., from public records or from a counterparty in possession of the data).
Automatic Collection Tools. In addition, we automatically collect certain data from Data Subjects who visit the Site. To this end, we use data collection tools (“Cookies”) on the Site to record certain usage information, such as the number and frequency of visitors to the Site. This information may include the websites that you access immediately before and after your visit to our Site, and which Internet browser you are using.
If you are located outside of the United States, please be aware that the Personal Data we collect will be processed and stored in the United States, a jurisdiction in which the data protection and privacy laws may not offer the same level of protection as those in the country where you reside or are a citizen.
How and on what basis do we use your Personal Data?
We use your Personal Data for a variety of reasonable and legitimate business purposes, including, but not limited to, the following:
- Complying with legal or regulatory obligations, such as our obligations regarding know-your-client and anti-money laundering;
- Performing a contract with you or to take steps at your request before entering into a contract, including to: (i) provide you with information regarding Sanguine products or services, (ii) assist you and answer your requests, (iii) evaluate whether we can offer you a Sanguine product or service and under what conditions;
- Other legitimate purposes, such as:
- Communicating with Data Subjects;
- Performing activities relating to client management, financial management and administration;
- Creating, improving and developing our products and services;
- Conducting market research, surveys, and similar inquiries to help us understand trends, client and Site visitor needs;
- Investigating and resolving disputes and security issues and enforcing Legal Notice and other agreements;
- Monitoring and auditing compliance with internal policies and procedures, legal obligations and to meet requirements and orders of regulatory authorities; and
- Processing and considering applications for employment, including evaluating and confirming your suitability for the position and accuracy of any information submitted.
We will not use your Personal Data for any purposes inconsistent with this Privacy Notice without your permission.
With whom do we share your Personal Data?
Within Sanguine. We share your Personal Data among Sanguine entities for the purposes set forth above. In general, our group entities, in turn, are not permitted to share your information with other non-affiliates entities, except as described herein or otherwise permitted by applicable laws.
To Third Parties. We share your Personal Data with third parties in certain circumstances, including the following:
- Service Providers. We share Personal Data with service providers that perform services on our behalf (e.g., third-party service providers to operate the Site). These companies may have access to your Personal Data but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We generally require these providers by contract to keep the information confidential.
- Transaction or Other Corporate Event. Your Personal Data can be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It also can be disclosed in the event of insolvency, bankruptcy or receivership. In such an event, we will post prominent notice of the change in ownership.
- As Required by Law. We also disclose your Personal Data if we are required to make disclosures by applicable law or to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or as part of our legislative or regulatory reporting requirements.
How do we protect your Personal Data?
We take seriously the obligation to safeguard your Personal Data. Your Personal Data held by us will be kept confidential in accordance with applicable Sanguine policies and procedures. We will use all reasonable efforts to ensure that all Personal Data is kept secure and safe from any loss or unauthorized disclosure or use. All reasonable efforts are made to ensure that any Personal Data held by us are stored in a secure and safe place and accessed only by our authorized employees and transferees.
Keeping your Personal Data current
In general, we seek to ensure that we keep your Personal Data accurate and up to date. However, you are responsible for, and we kindly request that you inform us of, any changes to your Personal Data (such as a change in your contact details). To update or edit your Personal Data that we have on file, including your communication preferences, please contact us using the contact details set out under the “Contact and Complaints” heading below or by sending an e-mail email@example.com.
How long do we keep your Personal Data?
In general, we will process and store your Personal Data for at least as long as it is necessary in order to fulfil our contractual, regulatory and statutory obligations. Subject to those qualifications, our goal is to keep such data for no longer than necessary in relation to the purposes for which we collect and use the Personal Data (we refer to the purposes as set forth above). Sanguine will retain your Personal Data in accordance with our Books & Records Policy. If you have any specific questions in this respect, please feel free to contact us.
Contact and Complaints
Sanguine takes very seriously any complaints we receive about our use of your Personal Data. Questions, comments, requests or complaints regarding the Site or this Privacy Notice and/or our use of your Personal Data should be addressed to firstname.lastname@example.org.
Any Personal Data we receive from you when making a complaint will be treated in accordance with this Privacy Notice and only to process the complaint and check on the level of service we provide. Similarly, where inquiries are submitted to us we will only use the information supplied to us to deal with the inquiry and any subsequent issues and to check on the level of service we provide.
The Sanguineadvisors.com Site
Sanguineadvisors.com (“the Site) is operated from servers in the United States. BY USING THE SITE AND PROVIDING INFORMATION TO US, YOU CONSENT TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN THE UNITED STATES.
Please be aware that the Site may contain links to other websites hosted by third parties. Sanguine does not control and is not responsible for the content or privacy practices and policies of such third party websites. We encourage you to be aware when you leave the Site and to read the privacy policies of each third-party website, especially if such website collects Personal Data from you.