This policy sets out:
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Our contact details are set out at the end of this policy. For the purposes of European Economic Area data protection law, (the “Data Protection Law”), the controller in relation to the personal data processed in accordance with this policy is Development Partners International LLP (“DPI”) unless otherwise stated below.
Information we collect about you
We may process your personal data if:
- You or the company you work for are a client, an investor, a director or a beneficial owner of an investor, a service provider or a supplier of ours or of our affiliates, including funds advised by us and their general partners or investment managers as listed in the contact us section below (our “Group”).
- You or the company you work for use our or our Group’s products or services.
- You work for a client, an investor, a service provider or a supplier of ours or our Group, or for someone who uses our or our Group’s products or services.
- You are someone (or you work for someone) to whom we want to advertise or market our or our Group’s goods or services.
Information we collect from you or from a third party
We may process your personal data that we have either obtained from you, or obtained from somewhere else. Personal data which is not collected directly from you may be collected:
- From your employer in connection with your job and how it relates to us.
- If you use the website operated by us.
- From third parties we work closely with (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers).
Personal data relating to you that we process may include:
- Your name.
- Who you work for, and your job function or department.
- Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).
- Information about you that you give us by communicating with us by phone, by e-mail, via our website, via social media or otherwise. It includes information you give us or that we obtain when you use our website, obtain or use our or our Group’s services, enquire about a service or contact us to report a problem, or do any of these things on behalf of the person that you work for.
- Information relating to transactions with us involving you or the company you work for (for example, details of services that we or our Group have supplied to, or obtained from, you or the person you work for).
- Other information, including nationality information (including copies of identify documents such as a passport) relating to you which it is necessary for us or our Group to process in order to enter into or perform a contract with you or the company you work for.
- Information about events to which you or your colleagues are invited, and your personal information and preferences to the extent that this information is relevant to organising and managing those events and the travel relating to the events (for example, your dietary requirements, passport details).
Information that we obtain from you when you use our website may include:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
- Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), content you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our team.
Cookies and other technologies
What are cookies
The cookies we use
Strictly necessary cookies. These are cookies that are required in our legitimate interest for the operation of our website and services. They include the cookies that enable you to log-in to any secured areas.
In addition, DPI has activated the IP masking feature when using Google Analytics which means that Google anonymises the last octet of the IP address it receives from users’ devices. For more information see: https://support.google.com/analytics/answer/6004245
The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off. If you want to disable cookies on our site, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. For further details on how to disable cookies for the most popular browsers see below:
For Microsoft Internet Explorer:
1. Choose the menu “tools” then “Internet Options”
2. Click on the “privacy” tab
3. Select the setting the appropriate setting
For Google Chrome:
1. Choose Settings> Advanced
2. Under “Privacy and security,” click “Content settings”.
3. Click “Cookies”
1. Choose Preferences > Privacy
2. Click on “Remove all Website Data”
For Mozilla firefox:
1. Choose the menu “tools” then “Options”
2. Click on the icon “privacy”
3. Find the menu “cookie” and select the relevant options
For Opera 6.0 and further:
1. Choose the menu Files”> “Preferences”
Find out more
|Cookie||Name||Purpose and lawful basis||More information|
|DPI Cookie Acceptance||cookie_banner_dismissed||This cookie is used to record if a user has dismissed our cookie notice banner.||To re-instate the notice banner, delete the cookie_banner_dismissed cookie. Find out how at www.aboutcookies.org|
|Caching Helpers||w3tc_referrer||We use caching courtesy of the W3 Total Cache plugin to optimise performance of this site.||To find out more, read about W3 Total Cache.|
|Google Analytics||__utma, __utmb, __utmc, __utmz||These cookies are used to collect information about how visitors use our site, which we use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.||To find out more, click here for an overview of privacy at Google.
To find out how to opt out, visit https://tools.google.com/dlpage/gaoptout
How we use your information
Information you give to us
We will use this information to:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you or the company you work for and us or our Group including:
- supplying services to you or the company you work for or receiving them from you or the company you work for, as the case may be;
- complying with applicable legal obligations, including without limitation, anti-money laundering regulations;
- administering your/your company’s account with us or our Group;
- notifying you about changes to our or our Group’s service.
- Provide you with information about our or our Group’s services we feel may interest you or the company you work for, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See Our promotional updates and communications.
- Ensure in our legitimate interests that:
- content from our site is presented in the most effective manner for you and for your computer;
- we provide you or the company you work for with the information and services you request from us.
Information we collect about you from your use of our website
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to keep our website safe and secure.
- to improve our website to ensure that content is presented in the most effective manner for you and for your computer.
- to allow you to participate in interactive features of our website and related service, when you choose to do so.
- to comply with our legal obligations.
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email, telephone, post or via virtual datarooms about our and our Group’s products/services.
You can object to further marketing at any time by sending us an email to IRTeam@dpi-llp.com.
You can also request that we send marketing material to a non-personal email address instead of one which identifies you as an individual.
Who we give your information to
We may share your personal data with:
- Any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates, including funds advised by us, and their general partners or investment managers, and who support our processing of personal data under this policy
- Appropriate third parties including:
- our business partners, clients, suppliers and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the person that you work for;
- our auditors, legal advisors and other professional advisors or service providers including our Group’s appointed fund administrators;
- In relation to information obtained via our website:
- analytics and search engine providers that assist us in the improvement and optimisation of our site and subject to the cookie section of this policy.
Other disclosures we may make
We will disclose your personal information to third parties:
- If DPI or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, in order to respond to requests from competent regulatory authorities, in order to enforce or apply our terms of supply terms and other agreements with you or the company you work for, or to protect the rights, property, or safety of DPI, our Group, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
Where we store your information
DPI are an international business and the data that we process in relation to you may be transferred to and stored, at, a destination outside the country where you access this website. Where you are accessing this website in Europe your data may be transferred outside the European Economic Area (“EEA”) to a destination that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.
We may transfer your personal information:
- In order to store it.
- In order to enable us to provide services to and fulfil our or any member of our Group’s contract with you or the company your work for. This includes transaction fulfilment, processing of transaction details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our Group, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
- Where you are accessing this website from Europe we may transfer your personal information to the following countries outside the EEA:
|USA||– in relation to Google Analytic Services.
Google is certified under the EU-US Privacy Shield Framework which is subject to an EC adequacy finding, that it provides appropriate safeguards in the law for the protection and processing of transferred personal data (see: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active)
|EU-US Privacy Shield|
|USA||– in relation to Microsoft Office 365.
Microsoft is certified under the EU-US Privacy Shield Framework which is subject to an EC adequacy finding, that it provides appropriate safeguards in the law for the protection and processing of transferred personal data (see: https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active)
|EU-US Privacy Shield|
|Mauritius||– in relation to the ADP I fund and related entities||EC-approved standard contractual clauses within the group|
|Jersey||– in relation to the ADP I fund and related entities||EU-commission adequacy decision|
|Guernsey||– in relation to the ADP II fund and related entities and the ADP III fund and related entities||EU-commission adequacy decision|
How we protect your information
All information you provide to us is stored on our secure servers and IT systems. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
How long we keep your information
We keep personal data for the term of an investment in order to meet our or any member of our Group’s contractual obligations to you or the institution you work for and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
We retain contact information for promotional updates and communications for as long as you are a customer of ours or our Group or we have engaged with you about one of our funds, and for a reasonable period of time after – this will usually be up to when we are marketing our next fund (generally every four to five years). You can also object to us using such information for marketing purposes at any time (as mentioned in Our promotional updates and communications.
You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing about our future funds which we generally market every four to five years (as mentioned in Our promotional updates and communications);
- to request that your provided personal data be moved to a third party.
Your right to withdraw consent:
Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at firstname.lastname@example.org. You can also change your marketing preferences at any time as described in Our promotional updates and communications;
How to exercise your rights
You can also exercise the rights listed above at any time by contacting us at email@example.com.
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).
The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.
Changes to this policy
Please see information of our (data controller) entities which are responsible for our data processing:
Development Partners International LLP, a controller which administers and hosts this site and from which global and strategic decisions are made as the parent company, including providing investment advice to its direct and indirect subsidiaries in Mauritius, Guernsey and Jersey.
2 Jubilee Place
Tel: +44 20 7349 5030
Fax: +44 20 7349 5038
Where we process your details in connection with fund investments, our other group companies, which are also controllers and which make decisions relating to investment funds, are listed below.
Each controller listed below has appointed Development Partners International LLP as its EU representative. You can contact Development Partners International LLP instead of, or as well as, each of these companies.
DPI Management Limited
Tel: +230 467 3000
ADP I GP Limited
Tel: +44 1534 504 000
ADP II GP Limited
St Peter Port
Tel: +44 1481 734 300
ADP III GP Limited
St Peter Port
Tel: +44 1481 734 300
ADP III Equity GP Limited
St Peter Port
Tel: +44 1481 734 300