Privacy Policy
Overview – the key information you should be aware of
(A) Who we are:
We are Highland Europe (UK) LLP and Highland (Geneva) Sarl. In this policy, we refer to ourselves as “Highland”, “our”, “us” or “we”. We are the controllers of your personal information, and the owners and operators of this website (www.highlandeurope.com).
If you need them, our company numbers and registered offices are as follows:
Highland Europe (UK) LLP
OC375755
30 Golden Square, London, W1F 9LD
Highland (Geneva) Sarl
CH-660.2.328.011-0
Rue du Marché 18, 1204 Geneva, Switzerland
(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information which you can find here.
In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.
We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know by emailing [email protected].
(C) Who this policy applies to: This policy applies to:
1. Visitors to our website;
2. Investors in our funds or portfolio companies;
3. People who sign up to attend our events; and
4. Our suppliers, and employees of our suppliers, other business contacts and people who contact us with enquiries.
Depending on our relationship, we will collect and use your information in different ways. Please click on the links above to find out the information that we collect about you and how we use this information.
(D) What this policy contains: This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):
1. How we obtain your personal information here;
2. Collection of your personal information and how we use it here:
3. Our legal basis for using your personal information here;
4. How and why we share your personal information with others here;
5. How long we store your personal information here;
6. Your rights here;
7. Marketing here;
8. Where we may transfer your personal information here;
9. Links to other websites here;
10. Changes to this privacy policy here; and
11. Further questions and how to make a complaint here.
(E) Your rights to object: You have various rights in respect of our use of your personal information as set out in section 6. Two of the fundamental rights to be aware of are that:
1. you may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
2. you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.
You can find out more information in section 6.
(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.
The detail – the key information you should be aware of
1. How we obtain your personal information
1.1 You may provide us with your personal information voluntarily. We may also receive information about you from third parties (which we refer to as “third party sources” or “suppliers” throughout this policy); for example, where you are an investor in one of our portfolio companies, we may receive your personal information from that portfolio company.
1.2 You may give us personal information about yourself by using the online forms provided on our website, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us. If you are a supplier, you may also give us personal information about you when you are offering or providing services to us.
2. Collection of your personal information and how we use it
Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information. We refer to this as “personal information” throughout this policy.
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your contact information (including your name and email address);
(ii) information related to your business (including company name and the department you work in);
(iii) information provided when you correspond with us;
(iv) any updates to information provided to us;
(v) personal information we collect about you or that we obtain from our third party sources;
(vi) the following information created and recorded automatically when you visit our website:
(A) Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and platform. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages;
(B) Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads; and
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to allow you to access and use our website;
(ii) to receive and respond to enquiries from you through the website;
(iii) for improvement and maintenance of our website and to provide technical support for our website;
(iv) to ensure the security of our website;
(v) to recognise you when you return to our website, to store information about your preferences, and to allow us to customise the website according to your individual interests; and
(vi) to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.
Please see sections 2.5 for more details about how we use your personal information.
(c) A word about cookies
(i) Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.
(ii) Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.
(iii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here.
2.2 Investors in our funds and representatives of our portfolio companies
We collect, and process personal information relating to existing, potential and former investors in our funds, and representatives of our portfolio companies (e.g. the founders of those companies).
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name and contact details (including your postal and e-mail address);
(ii) your gender, marital status, date of birth, signature, nationality, place and date of birth, dependants, next of kin and emergency contacts;
(iii) information on your passport, driving licence and/or utility bills;
(iv) financial information (including bank account details, pension details, tax status and tax identification numbers);
(v) details of your shareholding;
(vi) information obtained during checks that we need to carry out (such as anti-money laundering checks), which may including information relating to criminal convictions and offences;
(vii) information provided when you correspond with us; and
(viii) any updates to information provided to us.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to advise on any funds in which you are an investor or potential investor, and to enter into and honour our contractual obligations with you;
(ii) to monitor the performance of our portfolio companies;
(iii) to comply with our legal and regulatory obligations and to detect and prevent crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial or other services to persons who may be subject to economic or trade sanction on an ongoing basis to liaise with or report to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it appropriate to cooperate, in relation to an investment;
(iv) to communicate with our professional advisers for the purposes of obtaining professional advice;
(v) to communicate with you and to respond to your enquiries; and
to contact you (including by telephone or post) with information about our investments or events which either you request, or which we feel will be of interest to you. Please see section 2.5 for more details about how we use your personal information.
(c) Special categories of data. In limited circumstances, some of the personal information that we collect about you or which you provide to us about you or your family members may be special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.
2.3 People who sign up to attend our events
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name, contact information (including e-mail address), your place of work or other professional role, and any dietary or accessibility requirements you may have;
(ii) information provided when you correspond with us;
(iii) any updates to information provided to us.
(b) How we use your personal information
We will collect use and store the personal information listed above to process your registration for the relevant event, and to communicate with you about the event. We will also use your contact details following the event to send you information relating to the event or that we think may interest you.
(c) Special categories of data. Some of the personal information that we collect about you may be special categories of data. Special categories of data include information about your physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name, contact details (including e-mail address, phone number and postal address), company details and job title;
(ii) information provided when you correspond with us;
(iii) any updates to information provided to us; and
(iv) personal information we collect about you from third party sources such as LinkedIn.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to enable us to purchase and receive products and services from you (including supplier due diligence, payment and expense reporting and financial audits);
(ii) to deal with enquires from you;
(iii) for health and safety records and management;
(iv) for security vetting and criminal records checks (where applicable and allowed by law); and
(v) for CCTV monitoring and other security of company facilities.
Please see sections 2.5 for more details about how we use your personal information.
(c) Special categories of data. In limited circumstances, some of the personal information that we collect about you or which you provide to us about you or your employees may be special categories of data. Special categories of data include information about your physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.
2.5 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
3. Legal basis for use of your personal information
3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you, to comply with the terms of use of our website which you accept by browsing our website and/or to comply with our contract to provide services to or receive services from you or your employer); or
(b) our use of your personal information is necessary for complying with our legal or regulatory obligations; or
(c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
(i) run, grow and develop our business (as well as the businesses of our group companies and portfolio companies);
(ii) operate our website;
(iii) select appropriately skilled and qualified suppliers;
(iv) carry out marketing, market research and business development;
(v) place, track and ensure fulfilment of orders with our suppliers; and
(vi) for internal group administrative purposes.
3.2 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
3.3 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at [email protected] and we will stop doing so.
4. How and why we share your personal information with others
4.1 We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).
4.2 We will share your personal information with the following third parties or categories of third parties:
(a) Service providers that host, maintain, service and develop our IT solutions and may access personal data stored within that solution when providing support and maintenance services;
(b) other service providers and sub-contractors, including payment processors, utility providers, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;
(c) companies that assist in our marketing, advertising and promotional activities; and
(d) analytics and search engine providers that assist us in the improvement and optimisation of our website.
4.3 We will also disclose your personal information to third parties:
(a) where it is in our legitimate interests to do so to run, grow and develop our business:
(i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
(ii) if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;
(b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(c) in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(d) to protect the rights, property, or safety of Highland, our staff or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.
5. How long we store your personal information
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
6. Your rights
6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at [email protected] at any time. You have the following rights:
(a) Right of access: You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer your information outside of the United Kingdom or the European Economic Area (“EEA”).
(b) Right to update your information: You have a right to request an update to any of your personal information which is out of date or incorrect.
(c) Right to delete your information: You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 11.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are, using the contact details in section 11.
(d) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 11.
We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 11.
(e) Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
(f) Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.
This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.
(g) Right to object: You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.
6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
6.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
7. Marketing
7.1 We may collect and use your personal information for undertaking marketing by email telephone and post.
7.2 We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership if you have consented to receive such electronic marketing information.
7.3 If you wish to stop receiving marketing communications, you can contact us by email at [email protected].
8. Where we may transfer your personal information
8.1 Your personal information may be used, stored and/or accessed by staff operating outside the UK or the EEA working for us, other members of our group or suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.
8.2 If we provide any personal information about you to any such non-UK and non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following:
(a) ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the recipient country is deemed to provide adequate protection for such personal data; or
(b) where we have in place standard model contractual arrangements with the recipient which have been approved by the UK Government or the European Commission. These model contractual clauses include certain safeguards to protect the personal data;
8.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at [email protected] at any time.
Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
10. Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.
11. Further questions and how to make a complaint
11.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact [email protected] We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
11.2 You may also make a complaint to the Information Commissioner’s Office, or the data protection regulator in the country where you usually live or work, or where an alleged infringement of applicable data protection laws has taken place. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
The practices described in this privacy policy statement are current as of July 2024.