Apax Partners LLP Privacy Statement
Apax and data privacy
Apax Partners LLP, each General Partner of the funds advised by
Apax Partners LLP (the "Apax Funds") and each of their respective
affiliates (collectively, solely for the purpose of this Privacy
Statement, "Apax" or "we" or "us" or "our") are committed to
protecting and respecting your privacy.
This privacy statement sets out the basis on which we will
process any personal information that we may collect about you as a
visitor to any Apax related website (including www.apax.com and www.apax.us.com) or to the premises of any Apax
entity, or any contact at any Apax related investor, potential
investor, customer, supplier or other business partner.
The information that we collect about you
We may collect and process the following information about
- Information that you provide: This is information about you
that you provide by filling in forms on an Apax website (or any
other form you provide Apax), providing a business card (or
similar), while attending an Apax related event or corresponding
with Apax by telephone, post, email or otherwise. It may include,
for example, your name, address, email address and telephone
number; information about your business relationship with Apax;
information about your professional role, background and interests;
and information relating to events.
- Information that our websites and other systems collect about
- If you visit our websites they will automatically collect some
information about you and your visit, including the Internet
protocol (IP) address used to connect your device to the Internet
and some other information such as your browser type and version
and the pages on the sites that you visit.
- Our websites may also download "cookies" to your device - this
is described in our separate cookie statement.
- If you exchange emails, telephone conversations or other
electronic communications with our employees and other staff
members, our information technology systems will record details of
those conversations, sometimes including their content.
- Some of our premises have closed circuit TV systems which may
record you if you visit our premises, for security and safety
- Other information: We may also collect some information from
other sources. For example:
- If we have a business relationship with the organisation that
you represent, your colleagues or other business contacts may give
us information about you such as your contact details or details of
your role in the relationship.
- We sometimes collect information from third party data
providers or publicly available sources for anti-money-laundering,
background checking and similar purposes, and to protect our
business and comply with our legal and regulatory obligations.
The uses that we make of your information
We may use your information for particular purposes including
- to operate, manage, develop and promote our business and, in
particular, our relationship with you or the organisation you
represent (if any) and related transactions;
- to send you emails containing marketing information which we
believe you will find relevant and interesting;
- to operate, administer and improve our websites and premises
and other aspects of the way in which we conduct our
- to protect the security of our premises;
- to protect our business from fraud, money-laundering, breach of
confidence, theft of proprietary materials and other financial or
business crimes; and
- to comply with our legal and regulatory obligations and bring
and defend legal claims.
We may from time to time review information about you held in
our systems - including the contents of and other information
related to your email and other communications with us - for
compliance and business-protection purposes as described above.
This may include reviews for the purposes of disclosure of
information relevant to litigation and/or reviews of records
relevant to internal or external regulatory or criminal
investigations. To the extent permitted by applicable law these
reviews are intended to be conducted in a reasonable and
proportionate way and where appropriate will be approved at an
appropriate level of management. They may ultimately involve
disclosure of your information to governmental agencies and
litigation counterparties as described below. Your emails and other
communications may also occasionally be accessed by persons other
than the member of staff with whom they are exchanged for ordinary
business management purposes (for example, where necessary when a
staff member is out of the office or has left Apax).
We will generally only process your personal information as
necessary so that we can pursue the purposes described above, and
then only where we are not aware that our processing does not
prejudice you or your privacy in a way that would override our
legitimate interest in pursuing those purposes. In exceptional
circumstances we may also be required by law to disclose or
otherwise process your personal information. We will tell you, when
we ask you to provide information about yourself, if provision of
the requested information is necessary for compliance with a legal
obligation or, on the other hand, if it is purely voluntary and
there will be no implications if you decline to provide the
information. Otherwise you should assume that we need the
information for our business or compliance purposes (as described
above). If you are uncertain as to Apax's need for information that
we request from you, please contact the Apax representative asking
for the information, or
Contact us (see below), with your query.
Disclosure and international transfer of your information
We may disclose personal information about you, where reasonably
necessary for the various purposes set out above, including:
- to other Apax entities;
- to your colleagues within the organisation that you
- to service providers who host our websites or other information
technology systems or otherwise hold or process your information on
our behalf, under strict conditions of confidentiality and
- to partners who run any events that you sign up to through our
- to a person who acquires any business and assets that
previously had any such information, or relevant parts of them;
- in exceptional circumstances:
- to competent regulatory, prosecuting and other governmental
agencies, or litigation counterparties, in any country or
- where we are required by law to disclose.
These disclosures may involve transferring your personal
information overseas. If you are dealing with us within the
European Economic Area (or the UK, after it has left the European
Economic Area), you should be aware that this may include transfers
to countries outside the European Economic Area / UK, which do not
have similarly strict data privacy laws. In those cases, where we
transfer personal data to other members of the Apax group or our
service providers, we will aim to ensure that our arrangements with
them are governed by data transfer agreements, designed to ensure
that your personal information is protected, on terms approved for
this purpose by the European Commission. Please
Contact us (see below) if you would like to know whether any
such agreements are in place or, if so, to see a copy.
Retention and deletion of your information
We will delete the information that we hold about you when we no
longer need it. Specific information about our record retention
policies is available on request. Please
Contact us (see below).
Note that we may retain some limited information about you even
when we know that you have left the organisation that you
represent, so that we can maintain a continuous relationship with
you if and when we are in contact with you again, representing a
You may have a right of access to the personal information that
we hold about you, and to some related information, under data
protection law. You can also require any inaccurate personal
information to be corrected or deleted. You can object to our use
of your personal information for direct marketing purposes at any
time and you may have the right to object to our processing of some
or all of your personal information (and require them to be
deleted) in some other circumstances.
If you wish to exercise any of these rights, please
Contact us as set out below. You can also lodge a complaint
about our processing of your personal information with the office
of the UK Information Commissioner (www.ico.gov.uk).
We welcome questions, comments and requests regarding this
privacy statement and our processing of personal information.
Please email email@example.com.
Changes to this policy
Any changes we make to this privacy statement in the future will
be posted to our websites (at www.apax.com and www.apax.us.com) and also available if you
Contact us. Please check back frequently to see any