AS BaltCap and its subsidiaries (the “BaltCap Group”) collect your personal data while respecting your right to privacy. This Privacy Notice (the “Notice”) is issued on behalf of the BaltCap Group and a reference to “BaltCap” shall mean the relevant company in the BaltCap Group that is the controller of your personal data and determines the purpose for which your data is processed and how it is used. Contact information of BaltCap’s offices in Estonia, Latvia, Lithuania, Finland, Sweden and Poland can be found in contacts. Your first point of contact for any information or request in relation to your personal data should be one of BaltCap’s offices or the following e-mail address: firstname.lastname@example.org .
Which personal data do we collect?
We collect only such personal data and to such an extent that is necessary for the purposes of our business as specified below. Most commonly, the personal data we collect will fall into one or many of the following categories:
- Identification data (name, date of birth, identification document details, etc.)
- Contact data (address, telephone number, e-mail address, etc.)
- Financial data (bank account details, income details, etc.)
- Professional data (professional position, employment history, etc.)
- Direct marketing data (e-mail address, your newsletter preferences, etc.)
How do we collect personal data?
We collect personal data that you provide to us (for example, when you communicate with us via e-mail, telephone or other channels; when you give us your business card; when you agree to receiving our newsletter or when you respond to our anti-money laundering check or other information request). In some cases, we additionally collect your personal data from other sources such as sector-specific newsfeed as well as public databases, search engines and webpages.
For which purpose do we use your personal data and on which legal basis?
We only collect and use your personal data when we have a specific purpose to do so. Most commonly, we use your personal data for one of the purposes listed below.
- For performance of our duties to the investment funds managed or advised by BaltCap, we use mainly the identification, contact and professional data of the representatives of the investors. The legal basis for the processing is the performance of a contract.
- For communication with potential investors, we use mainly the identification, contact and professional data of the representatives of the potential investors. The legal basis for the processing is the pursuance of our legitimate interest to conduct our business of raising, managing and advising private equity investment funds as well as (at your respective request) to take steps to enter into a contract.
- For evaluation of the funds’ potential investments and management and divestment of actual investments, we use mainly the identification, contact, professional and financial data of the board members, employees and other representatives of the potential or actual portfolio companies. The legal basis for the processing is, as appropriate, either taking steps at your respective request to enter into a contract, or the performance of a contract, or the pursuance of our legitimate interest to conduct our business of managing and advising private equity investment funds.
- For performance of another type of contract we have entered into with you or for taking steps to enter into a contract with you, we use mainly your identification and contact data as well as other data the processing of which is necessary, depending on the contract in question.
- For performance of anti-money laundering checks, we use your identification, contact, financial, professional and other data if and to the extent that is necessary for performing the anti-money laundering check. The legal basis for the processing is compliance with a legal requirement.
- For sending you newsfeed relating to our business, we use your name and e-mail address with your consent. You have the right to withdraw your consent at any time by using the “unsubscribe” option at the end of the relevant e-mail.
What if I do not provide my personal data?
Where we need to collect your personal data on the basis of a legal requirement (such as the anti-money laundering checks) or under the terms of a contract we have with you or for taking steps to enter into a contract with you, we might not be able to do business with you if you fail to provide the data requested.
With whom do we share your personal data?
In the context of the purposes outlined above, we share your personal data with third parties. Such third parties include other companies in BaltCapGroup, our service providers (including for example IT and telecommunications, business management software, fund administration), professional advisers (including for example lawyers, financial advisors, banks, auditors and insurers), and regulators and other authorities. We only disclose your personal data to such third parties that have ensured us to implement adequate safeguards to protect the security of your personal data and use it in accordance with the law. Where relevant, we enter into data processing agreements with the third parties stipulating their obligations in respect of handling your personal data.
Some of the third parties we share your personal data with may be located outside of the European Union. In such case, we make sure that at least one of the following safeguards is in place:
- The country we transfer the data to has been deemed to provide an adequate level of protection for personal data by the European Commission.
- The recipient of the data is bound by a contract approved by the European Commission which gives personal data the same level of protection it has in the European Union. For further details, please refer to: Standard contractual clauses for data transfers between EU and non-EU countries.
How long will we keep your personal data?
We will keep your personal data for only as long as is necessary for the purposes outlined above or where we are relying on consent to process your personal data until you withdraw your consent, unless we are required to continue storing such data for a longer period of time due to legal, accounting or reporting requirements. Where we are in doubt about what the appropriate retention period of a certain category or item of personal data is, we consider the nature and scope of the data, the context and purposes of processing such data as well as the risk of harm to the rights and freedoms of the person concerned in the event of a data breach, in order to finally determine the appropriate time for deleting the data.
What measures do we apply to protect your personal data?
BaltCap shall ensure the confidentiality of your personal in accordance with the requirements of the legislation in force and the implementation of appropriate technical and organizational measures intended for the protection of your personal data from illegal access, disclosure, accidental loss, amendment or destruction or other illegal management.
What are your rights as a data subject?
Personal data is yours, so you have a right to the information and can influence how we handle your personal data. The following is a brief summary of your rights:
The right of access to personal data. You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed and information about how that data was collected, used, shared, and so on.
The right to data portability You have the right to receive personal data concerning you in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller.
The right to object to the processing of data. You have the right to object to the processing of data on which we base a legitimate interest as well as where personal data are processed for direct marketing purposes.
The right to erasure („the right to be forgotten“). You have the right to request that we delete your personal data, for example if the data are no longer needed for the purposes for which they were collected or otherwise processed, or if there is no legal basis for processing the data. However, we may have a legal basis to store such data, in which case they will not be deleted.
The right to have data rectified. You have the right to request that we correct inaccurate or incomplete information about you.
The right to restrict data processing. You have the right to request that the processing of our personal data be restricted until we correct your inaccurate or incomplete data or until we have examined your objection.
The right to withdraw your consent. You have the right to withdraw any consent given to us at any time. Please note that this will not affect any processing that took place before the withdrawal of consent.
You may exercise your abovementioned rights in accordance with the requirements of applicable EU and local laws by contacting one of our offices or via e-mail to email@example.com.
If you believe that we have processed your personal data incorrectly and your privacy rights have been breached, you have the right to contact the supervisory authority. You can lodge a complaint with the supervisory authority in the country where you live or work. Contact information for these authorities can be accessed here: European Commission: An overview of the National Data Protection Authorities.
Cookies are small text files placed on your computer or other device you use to visit our website. Cookies ensure that the website works as well as possible. They also provide us with information for you to have a good user experience and for it to be easy for you to use the website.
Cookies can be used to collect information on, for example, from what website the visitor has come, what websites are browsed and when, and what browser and IP-address the device uses.
Managing cookies on our website
More information on how to manage and disable cookies in your browser:
You can also manage and disable the cookies (except essential cookies) on our site by clicking on the “Cookie Settings” button.
In addition, you can control third party cookie use at Your Online Choices.
If you want to learn more about cookies and how to manage or delete them, please visit https://www.allaboutcookies.org
If you want to learn how to disable website tracking using Google Analytics cookies, please visit https://tools.google.com/dlpage/gaoptout
Types of cookies
There are different types of cookies depending on the life span and origin:
- Session cookies allow users to be recognized for the duration of a single session so that any page changes or item selection are remembered when they move from page to page. These cookies make navigating across numerous website pages faster and easier because there is no need to repeatedly process the information when a new page is opened. Session cookies are temporary and disappear once you close your browser or log off the website.
- Long-term cookies are stored on your computer for a specified period of time following the end of your session and they may be recording specific user settings or actions when the user returns to the website.
- First-party cookies are placed on your device by us and collect information that we use.
- Third-party cookies are provided by other than us and are used, for example, to collect information for advertising and tailor-made content as well as for web statistics.
Cookies are also categorized into different types based on functionality:
- Necessary cookies are needed for our website and all functions to work. These cookies do not store any personally identifiable information.
- Preference cookies are used for improved functionality and personalization, e.g. language.
- Statistic/analytical cookies help to count the number of website visitors, see where the visitors come from and what parts of the website are used most, so the website and its performance could be improved.
- Marketing cookies are used to promote us, usually on third party websites, by collecting information about your activities on our website. Thanks to the information gathered, marketing becomes as relevant and interesting to you as possible.
- Social media cookies are used by social media service providers to recognize the user so that you can, for example, share articles in the service by pressing a button. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
Any information collected using cookies is stored until these cookies expire and is not used for any purpose other than those listed in this policy.
You have the right to request access to your data that we have collected using cookies. If your personal data is inaccurate, incomplete or non-current, you are entitled to have it rectified.
If you have any questions or want to exercise your rights, please contact us by email at firstname.lastname@example.org or reach out to us via other channels indicated on this website.
Updates to the Notice
This Notice was last updated on 23 May 2023. We reserve the right to change this Notice from time to time by publishing the updated Notice on our webpage.