Where used in this Policy, “Sparring Capital”, “Sparring” or “the Firm”, shall mean Sparring Capital SAS For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the “Data Protection Laws”), Sparring is the controller of your personal information.
Personal information of business contacts
If you have had contact with Sparring, for example from a previous meeting or making contact with the Firm, we may store limited amounts of personal information relating to you, such as your name, job title, employer organization, (potential) transactions that we have discussed and contact details. We will collect and store this personal information for the purposes of :
- providing periodic business updates (see below);
- organizing meetings between you and Sparring ’s team;
- inviting you to events; and
- similar communication of a professional nature.
The personal information we hold about business contacts may be shared with companies who process personal information on Sparring ’s behalf or professional advisors, for example accountants, lawyers or other consultants.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running and promoting our business.
Personal information of suppliers and professional advisors
If you are a supplier or professional adviser to Sparring Capital, we will store limited amounts of personal information relating to you, including your name, job title, qualifications, employer organization, (potential) transactions that we have discussed and contact details. We will store this personal information for the purposes of administering and maintaining records of services or advice we have received, commissioning further services, and for other purposes of this nature.
The personal information we hold about suppliers and professional advisors may be shared with companies who process personal information on Sparring ’s behalf or professional advisors, such as accountants, lawyers or other consultants.
In accordance with the Data Protection Laws, our legal basis for storing personal information that you provide to us is that such storage is necessary for our legitimate interests in running and promoting our business.
Personal information of actual/potential management teams
If you are involved in a transaction that Sparring and/or the funds that it manages enters into, or a potential transaction that Sparring considers, we may store personal information such as: your CV, details of your previous employment history, your financial status and dealings, nationality information (including copies of a passport etc), references provided by third parties, and results of other due diligence carried out. This information is collected and stored in order to :
- assess and administer actual and/or potential transactions;
- assess suitability for involvement of management teams in transactions;
- complying with our policies as well as regulatory and legal obligations, including assessing and managing risk;
- safeguarding our legal rights and interests;
- seeking and receiving advice from our professional advisors; and
- providing periodic business updates, as described below.
The personal information we hold about actual and/or potential management teams may be shared with:
- companies who process personal information on Sparring’s behalf and third party outsourced services providers;
- financial intermediaries and professional advisors;
- other persons who have an interest or involvement in, or who are considering an interest or involvement in, a (potential) transaction for Sparring, for example: co-investors, finance providers and investors in the funds managed by Sparring Capital.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that its processing is necessary for our legitimate interests in running our business. Should we enter into a transaction with your involvement, it will also be necessary to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.
Mandatory provision of information
We shall explain to you when the provision of particular information is mandatory and the possible consequences of not providing particular information. Sparring will only process the personal information you provide to Sparring for the purposes listed above.
Sensitive or special category personal data
Different rules apply to data concerning race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences – these are all called sensitive or special category personal data. Please do not send us sensitive personal data as generally we do not need it.
International transfers of personal information
In the event that Sparring Capital transfers personal information to third parties outside of the EEA, we shall endeavor to ensure that those transfers take place in accordance with the Data Protection Laws, for example by entering into data transfer agreements with the recipient.
By using our website without adjusting your web browser to block them, you are consenting to these types of cookies being stored on your device.
Periodic business updates
We may use personal information that we hold to send you periodic updates about Sparring Capital’s business, activities and opportunities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us (see “Sparring Data Privacy Contacts” below), or by clicking the “Unsubscribe” link in any email that you receive.
Retention of personal information
The period for which Sparring will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. For example, if you provide us with your information in connection with a potential management position with one of our portfolio companies, we may keep your information for up to fifteen years from the date of last contact with you.
Individuals whose personal information we hold may be entitled to access their personal information, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. Any such request should be submitted in writing to the Administrative team of Sparring Capital (firstname.lastname@example.org).
Accuracy and security
Sparring will take all reasonable steps to keep your personal information accurate and, where necessary, up to date. If you believe that any of the information that Sparring Capital holds about you is incorrect please notify us (see “Sparring Data Privacy Contacts” below).
Our team will take all reasonable steps to protect the confidentiality and security of your personal information, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Sparring responsible for any breach of security unless this is due to Sparring ’s negligence or willful default.
Sparring Capital Data Privacy Contacts
For all enquiries, please email email@example.com.