Privacy Notice

1. Introduction

This privacy notice (the “Privacy Notice”) describes what, how and why Mangrove Capital Partners S.A. (“Mangrove”, “we”, “us”, or “our”) collects the information about you that we do, and what we do with that information. Mangrove is committed to protecting your personal data and respecting your privacy. We may collect, process and retain personal information when we interact with you, whether you are a visitor to our website or corresponding with us via email, telephone or otherwise. All data that we may collect and process from time to time will be collected and processed in accordance with all applicable laws, including without limitation, the General Data Protection Regulation (the "GDPR") and any related legislation arising therefrom ("Applicable Laws") and for the purposes defined below.

2. Terminology

Personal Data: any information relating to an identified or identifiable natural person.

Data Subject: a living individual to whom Personal Data relates. 

Data Controller: the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data.

 

Mangrove acts as a Data Controller of your Personal Data.

3. Types of personal data that Mangrove may collect and process

Identification Data. Includes first name, maiden name, last name, username or similar identifier, passport/ID card data, and tax identification numbers. 

Administrative Data. Includes marital status, title, date of birth, and gender.

Contact Data. Including billing address, correspondence address, email address, and telephone numbers. 

Professional Data. Includes job/occupation, employer, positions and mandates held, and employment and education history. 

Financial Data. includes bank account details and bank statements and financial transaction data.

Numeric Data. Includes internet protocol (IP) address and log-in data.

Marketing and Communications Data. Includes any preferences in receiving marketing from us. 

4. How we collect Personal Data

We may collect Personal Data through direct interactions, automatic technologies or interactions and/or from third parties or publicly available sources, including without limitation:

  • through the Mangrove website (https://www.mangrove.vc/).

  • through email, telephone and other communications in the course of our business relationship with you.

  • through physical meetings with our staff members (e.g. the exchange of business cards and presentations).

5. For what purposes we collect Personal Data

Purpose / Activity

Type of Data

Lawful basis for processing

(a) Identification

(b) Administrative

(c) Contact

(d) Professional

(e) Financial

Necessary to comply with our legal obligations.

(f) Identification

(b) Contact

Necessary for our legitimate interest of communicating and responding to you/

(a) Identification

(b) Contact

Necessary to comply with our legal obligations.

Necessary for our legitimate interests in growing our business with the best team.

Compliance with applicable laws and regulations

To ensure compliance with our legal and regulatory obligations, including (without limitation) under applicable anti-money laundering, data protection and tax legislation.

General correspondence

To respond to any enquires you may have and reply to your enquiries.

Job applications

To consider any applications.

Necessary for the performance of a contract with you.

Necessary to comply with our legal obligation.

Necessary for our legitimate interests of conducting our biasness securely and privately with our investors.

(a) Identification

(b) Contact

(c) Professional

(d) Financial

(e) Numeric 

Investors portal 

To provide our investors with sensitive information in a secure manner and to manage our web-based services and supporting infrastructure.

Investment evaluation 

To assess pre-investment opportunities and carry out primary due diligence.

(a) Identification

(b) Contact

(c) Professional

Necessary to comply with legal obligation.

Necessary for our legitimate interests in conducting our business and investing in new portfolio companies.

Administration

To maintain its administrative and business relationship management systems, including (but not limited to) on-going transactions monitoring, invoicing and invoice payments, complaints handling and quality assurance.

(a) Identification

(b) Administrative

(c) Contact

(d) Financial

(e) Marketing and Communications Data

Necessary for our legitimate interests in conducting our business.

Cookies

To record the usage of our website.

(f) Technical

Necessary for our legitimate interest of studying how our site is used to keep it relevant and up to date. 

Sending marketing to you

To send you direct information and marketing concerning our business.

(a) Identification

(b) Contact

(c) Marketing

Necessary for our legitimate interests in providing you with information and promoting our products and services. 

6. Sharing of Personal Data with third parties

If you are contacting us on behalf of a potential portfolio company, or if you intend to engage with us in any other business transaction, we may need to transfer your Personal Data to a third party for processing where this is required in connection with the purpose for which it was collected. We may be legally, contractually or otherwise obligated to share your Personal Data with (a) other entities within our group, (b) professional advisers, including lawyers, bankers, auditors and insurers, (c) regulators and government bodies, (e) IT service providers, (f) any other third party service where the transfer of information is required in connection with the purpose for which it was collected.

7. International transfers of Personal Data

Although Mangrove is situated in Luxembourg, it is an international business. In the processing of Personal Data, we may therefore be required to transfer Personal Data to a party that is not bound by European legislation, including the GDPR. Where this is the case, we will ensure your information is adequately protected and safeguarded by contractual, technical and organisational means.  

8. Retention of Personal Data

We will only retain your Personal Data for as long as necessary to achieve the purpose for which it was collected. We will retain the Personal Data for the purpose of satisfying our legitimate interests, as well as any legal, regulatory, reporting and accounting requirements associated with our business and other dealings relating to Personal Data. While retaining your Personal Data, we will ensure that it is secure from unauthorised use or disclosure. Once your Personal Data is no longer required for the purposes for which it was acquired, it will be securely destroyed in accordance with applicable laws and regulations. 

 

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you. 

9. Your rights concerning your personal data

If the processing of your Personal Data is within the scope of the GDPR you have certain rights that you can exercise in connection with your Personal Data: These are the rights to:

  • Request access to your Personal Data through a data subject assess request. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

  • Request rectification of your Personal Data. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with applicable law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:

    • If you want us to establish the data's accuracy.

    • Where our use of the data is unlawful but you do not want us to erase it.

    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your Personal Data to you or to a third party. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: 

    • If you want us to establish the data's accuracy. 

    • Where our use of the data is unlawful but you do not want us to erase it. 

    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 

    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

This Privacy Notice acts as a primary safeguard to inform you of your data rights. If we require additional Personal Data that is not outlined in this Privacy Notice, we will supply you with a supplementary privacy notice that will outline the use and purpose of such additional collection of Personal Data. 

10. Changes

This Privacy Notice aims to be accurate and clearly reflective of our current practices with respect to how we process your Personal Data. If any changes to our website or changes to legislation require a change to our Privacy Notice, we will make these changes clearly visible on our website. Please do check this Privacy Notice often to confirm any changes. Additionally, if the information that you have previously submitted to us is no longer accurate, it remains your responsibility to notify us of any changes to our recorded information. 

10. Contact

If you require any additional details or information or would like to exercise any of your data privacy rights, please contact us using the following contact details: legal@mangrove.vc