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Privacy policy

Investcorp Europe Acquisition Corp. I, a Cayman Islands exempted company with a mailing address at Century Yard, Cricket Square, Elgin Avenue, PO Box 1111, George Town, Grand Cayman, Cayman Islands, KY1-1102 (“we”, “us”, and “our”) has created this privacy statement to demonstrate our commitment to data privacy. Your right to data privacy and data security is a primary concern. This privacy statement sets out the basis on which any information we, as data controller, collect from you, or that is provided to us, will be processed by us.

Please find below further information regarding the ways in which we process your personal data and your rights in relation to such data processing such data.

1. INFORMATION GATHERING AND USAGE

Why personal data is used

We intend to give you as much control as reasonably possible over your personal data (i.e., information that can be used to identify you, such as your name, email address, telephone numbers, postal address, credit card information, etc. or which relates to you). There are times when we may need to collect and process personal data from you to provide you with the services that you have requested from us. Set out below is a list of the types of personal data we might collect from you and the purposes for which we would use it.

  • Client onboarding, account opening, and maintenance: We collect information in relation to know your client (“KYC”) compliance checks prior to opening your account or effecting your investments to enable us to identify and verify the identity of prospective clients in accordance with anti-money laundering regulations. We also conduct KYC checks from time to time to ensure the information we hold on you is up to date. This may include your name, title, date of birth, passport copy, social security number, driving license (or other government identification documents), address, email, phone number, nationality, citizenship, marital status, tax details, board information (i.e., directorships), income, salary, source of funds, academic record (including degrees and schooling), licenses, and professional memberships.
  • Providing services to you (including any subscription or redemption): We collect information to enable us to market and deliver existing and new services to you, provide you with investor reports about your portfolio of investments, etc. This may include bank details, account balance, transaction history, investing preferences, investment history, risk tolerance, and wire transfer instructions.
  • Personalize our products and services: We collect online identifying information through the use of cookies (please refer to our cookie policy) and analytics tools to allow us to tailor our website in accordance with your preferences. This may include information on your location to show the version of the site most relevant to your location, your usage of our website (e.g., user movement including page scrolling, clicks, text entered, etc.) to help us identify usability issues and improve the service delivered to you, and device information to ensure we show you the best version of the site suited to your device. Offline, we may retain information about the investments and products you are most interested in so that we know what opportunities to inform you of in future.
  • Special events: We may collect information from you when we organize special events to which you subscribe, to enable us to better service your needs during your attendance at such events. We may take photographs at our events, and it is possible that such photographs will include your image. We take such photographs for use in promotional materials for future events and we may upload these photographs to our website or microsites that we create for such events and/or as part of press releases or social media posts.
  • Marketing:  We may send you information about products and services you might like. You have the right at any time to stop our Company from contacting you for marketing purposes or giving your data to other members of our Company Group. If you do so, we will log your objection, stop processing your data for direct marketing purposes, and we will not contact you again for such purpose.
  • Compliance with legal or regulatory obligations: We collect information in relation to compliance with our legal and regulatory reporting obligations. This may include executed share purchase agreements, transaction histories, certifications related to FATCA/CRS or other tax reporting requirements, etc.
  • Visitors to our offices: If you visit our offices, we will collect information about you (such as your name and contact details, details of your appointment and the relevant Investcorp group team members you are meeting, and the time and date of your visit) to enable us to verify your identity and record the fact of your visit for security and health and safety purposes.

We may receive the above personal information from sources other than you directly, e.g., from investor transactions with us and our affiliates, and from banks in connection with investor transactions or from investor representatives.

We also note that telephone conversations and instructions may be recorded, as proof of a transaction or related communication. Such recordings will be processed in accordance with the applicable data protection laws and shall not be released to third parties, except in cases where we or any other relevant entities are compelled or entitled by laws or regulations or court order to do so.

Failure to provide your personal data may mean that we are not able to communicate with you or have a business relationship with you.

We do not perform any regular automated-decision-making activities, including profiling activities, where your personal data is processed by automated means, except as described above in relation to the use of cookies.

We will only process your personal data if and to the extent applicable law provides a lawful basis for us to do so and in particular:

  • if you have consented to us doing so;
  • if we need it to perform the contract, we have entered with you;
  • if we need it to comply with a legal obligation; or
  • if we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests will be the provision of services by us, requests, administrative or operational processes within Investcorp group, promotion of our products and special events, direct marketing, the provision of the proof, in the event of a dispute, of a transaction or any commercial communication as well as in connection with any proposed purchase, merger or acquisition of any part of our business, compliance with foreign laws and regulations and/or any order of a foreign court, government, supervisory, regulatory or tax authority, risk management, and exercising our business in accordance with reasonable market standards.

With whom personal data may be shared

  • Within Investcorp group. We may share the personal data that you provide to us to other entities in the Investcorp group to the extent necessary for the purpose of providing services to you.
  • To third parties for Business Purposes. We may share the personal data that you provide to us to our service providers for the purpose of providing services to you. This may include the provision of your personal data to IT service providers, fund and other administrators, marketing advisors, legal and other professional advisors, and other service providers we may deal with from time to time. We may also provide your personal data to any successor, or potential successor, to all or part of our business (or otherwise as necessary in connection with an investment into or transaction related to our business). We are also regulated in various jurisdictions and have reporting obligations and other regulatory requirements that may require us to disclose your personal data to those regulators. Furthermore, to conduct our business activities, we are often required by our counterparties who perform their own KYC procedures to provide certain information to them relating to our beneficial owners or the beneficial owners of the investments arranged by us.
  • Security. We will also process your personal data for the purpose of ensuring office security and for health and safety purposes.
  • Photographs. As noted above, we use photographs we take at events to promote future events. Such photographs may include your image where you attend an event and we may publish these photos on our website, microsite, or as part of a press release or in a social media post.

We will not otherwise use, share, disseminate, publish, or disclose your personal data (except as may be required in response to litigation, investigations, or other legally required disclosures).

2. WHERE WE STORE AND/OR TRANSFER YOUR PERSONAL DATA

We may transfer your personal data to, or store it in, a destination outside of the jurisdiction of the entity to which you provided it or the jurisdiction in which you are located. This is because Investcorp group is a global business, with operations located in various jurisdictions, which uses service providers based in several locations worldwide. In some cases, your personal data will be stored in or transferred to jurisdictions outside of the European Union (“EU”) or the European Economic Area (“EEA”) (a third country), where data protection laws are not as stringent as the applicable laws under the European Union or EEA regime.

Where we have to transfer your personal data from the EU or EEA to third countries, we will use appropriate approved safeguards, including the European Commission’s standard contractual clauses.

For further information please do not hesitate to contact us using the details below.

Period for which we store your personal data

We will store your personal data for only so long as is necessary to fulfil the purposes described above and in accordance with data retention periods prescribed by applicable laws and regulations. We regularly assess our need to retain personal data by reference to the purposes for which it was collected.

Once our relationship with you has come to an end, we will retain the personal information for a period that enables us to maintain business records for analysis or audit purposes, comply with record retention requirements under applicable laws, defend or bring existing legal claims, and/or deal with any complaints about our services subject to any limitation periods imposed by law.

Where it is no longer necessary to retain the data (and where legal obligations do not mandate further retention) we will securely delete your personal data.

Links to third-party websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information? which you provide whilst visiting such websites and such websites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Message boards/forums

This website may make forums and message boards available to you. Please remember that any information that is disclosed in these areas becomes public information. You should exercise caution when deciding to disclose your personal data.

Electronic newsletters

We may from time to time offer various free electronic newsletters. We do not spam, sell or rent email addresses and we will only send you our newsletter where we are complying with applicable laws regulating direct marketing. You may object to receiving newsletter and remove your address from our mailing lists by sending us an email.

3. YOUR RIGHTS

Residents of the EU and United Kingdom have rights regarding our processing of your information under applicable laws. These rights may include the following:

Access. You may contact us at any time to request access to the personal information we hold about you. We will confirm whether we are processing your personal data, provide details of the categories of personal data concerned and the reasons for our processing. We can also provide you with a copy of your personal information on request.

Rectification. We rely on you to provide accurate, complete, and current personal data to us. If the information we hold appears to be inaccurate we will not use it, and not allow others to use it, until it is verified. You can ask us to correct or complete your personal data by contacting us at any time. To the extent possible, we will inform anyone who has received your personal data of any corrections we make to it.

Restriction. In certain circumstances, it may be possible to require us to limit the way in which we process your personal information (i.e., require us to continue to store your personal data, but not otherwise process it without your consent). Such circumstances include:

  • where you think the data we hold about you is inaccurate, processing can be restricted while it is being rectified;
  • where you object to our processing, (which is being carried out on the grounds that it is necessary in the public interest or for our legitimate interests) processing can be restricted while we determine whether such grounds override your interests;
  • where processing is unlawful but you oppose the erasure and request restriction of your data instead; and
  • where we no longer need the personal data, but you require the data to establish, exercise or defend a legal claim, our processing can be restricted.

Erasure. You may ask to have the information on your account deleted or removed. We will try to do so promptly, and, to the extent possible, we will inform anyone who has received your personal information of your request. However, we must keep track of certain transaction information, such as past purchases / investments and similar information, for legal compliance purposes, so we may not be able to fully delete your information in certain circumstances.

Receiving/transferring your personal data. In certain circumstances you may also ask us to send you the personal data we hold on you in an electronic, structured, and user-friendly format, or you may ask us to send this data to another organization, under certain conditions.

Object to Processing. Where we are processing your personal information without your consent to pursue our legitimate interests, you may object to us processing your personal data. Where we are using your personal data to contact you for marketing purposes, you may object to such processing at any time.

Automated decision-making. You have the right to be informed of any automated decision-making, including profiling, used in connection with your personal data, and we will provide information about the logic we apply, as well as the significance and consequences of such processing.

For any of the requests listed above, please contact us. Our response to such requests may be limited to information under our direct control.

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, if your request for access is excessive or unjustified, we may charge a reasonable fee.

4. SECURITY

Security measures

Protecting your information from unauthorized disclosure is important to us. We have appropriate technical and organizational security measures in place to help protect against the loss, misuse, and alteration of the information under our control. We limit access to personal data that we collect about you to our employees and third-party agents, who we reasonably believe need to have access to your information to provide you with the information or services you request from us. While we cannot guarantee that loss, misuse, or alteration to data will not occur, we ensure that our systems adhere to market security standard to help safeguard against such occurrences.

Where information is provided to us via our website, in certain areas the information passed between your browser and our system is encrypted with secure sockets layer (“SSL”) technology to create a protected connection between you and our website to ensure confidentiality. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. We will use commercially acceptable means to protect your personal data, but we cannot guarantee its absolute security. We encourage you to use caution when using the Internet. If you have any questions about our security, you can email us at [email protected].

Children’s privacy protection

This Platform is meant for adults. Investcorp does not target children and its websites are not intended for children under the age of 16. Investcorp will not knowingly collect personal data from children and will delete such data upon discovery. Where Investcorp requires personal data pertaining to children for the purpose of providing a service, the consent of an adult with parental responsibility for that child will be required. If you are a parent or legal guardian and think your child under 16 has provided us with information, please contact us at [email protected]

5. OPTING OUT

If you do not wish to receive certain communications from us you may opt out by: (1) declining the service offered or (2) informing us that you no longer wish to receive such communications by contacting us at Century Yard, Cricket Square, Elgin Avenue, PO Box 1111, George Town, Grand Cayman, Cayman Islands KY1-1102 or [email protected].

We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.

6. CHANGES IN POLICY

From time to time, we may change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on our Platform. Please check our Platform periodically for updates.

7. CONTACT DETAILS

If you would like to contact us with regards to your personal data, to exercise any of the rights listed above, please contact us at:

Data Protection, Investcorp Europe Acquisition Corp. I, Century Yard, Cricket Square, Elgin Avenue, PO Box 1111, George Town, Grand Cayman, Cayman Islands KY1-1102 or [email protected].

8. COMPLAINTS

Should you wish to report a complaint or if you feel that our Company has not addressed your concern in a satisfactory manner, you can register a complaint about our handling of your personal data with the Information Commissioner’s Office, who are the supervisory authority for UK GDPR. www.ico.org.uk/concerns

In addition, you may contact the Data Protection Authority where you reside, where you believe the infringement has occurred or where you believe that we have not resolved an issue you have raised with us.

Effective Date:   April 2022