This statement sets out how Hermes GPE LLP (‘Hermes GPE’) is committed to protecting the privacy and security of your personal data (‘personal information’). It also gives you information on how your personal information (ie information which directly or indirectly identifies you) is processed.
Who is Hermes GPE?
Hermes GPE is a leading investor in global private equity. We act as an investment manager and advisor, specialising in developing bespoke and diversified portfolios for clients that provide access to investment opportunities in buyouts and growth equity. Investments are made both via funds and by direct / co-investments, with the aim of offering clients the best and most relevant investment opportunities that match their risk / return criteria. Hermes GPE is authorised and regulated by the Financial Conduct Authority in the United Kingdom and is an approved Alternative Investment Fund Manager, an approved promoter with the Guernsey Financial Services Commission, a Registered Investment Adviser with the United States Securities and Exchange Commission and has a financial services exemption with the Australian Securities and Investment Commission. Hermes GPE (Singapore) Pte Ltd, a subsidiary, is regulated by the Monetary Authority of Singapore.
Collecting your personal information
We may collect certain personal information with respect to the representatives of institutional clients, other business relationships and employees/applicants, by way of example:
- Name and contact details
- Tax information
- Nationality, passport or other identification documents
- Details of role responsibilities
- Information on investigations, litigation, court proceedings, civil liabilities or criminal convictions against you
- Employee information required for HR purposes (including payroll, job history)
- Where permitted, information received from credit reference agencies, fraud prevention agencies and from other public sources such as Companies House, and
- We monitor and/or record your telephone calls and electronic transactions.
How we will use your personal information
We will use your personal information for:
- The provision of products and/or services to clients or investors in our funds
- Managing business relationships with you
- Archiving documents (electronic and paper based)
- Detecting and preventing fraud and/or money laundering
- Statistical analysis and assessment,
- Job applicants, employee and training records
- Communicating with you, and
- Otherwise as is necessary to comply with applicable laws, regulations and/or codes of practice.
The provision of personal information by you may be necessary in order for us and other third parties (to which personal information is disclosed) to provide you with the requested services, for the performance of any contractual relationship with you and for the other purposes as set out in this notice where in our legitimate interests.
How we disclose your personal information
We may disclose certain personal information:
- To Hermes Investment Management which consists of Hermes Fund Managers Limited and its subsidiaries which provides certain services to us on an outsourced basis
- To courts, governmental and non-governmental regulators, tax authorities and ombudsmen
- To law enforcement agencies or as otherwise required under law or regulation;
- To any third party that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or a part of its business, whether by merger, acquisition, reorganisation or otherwise
- To credit reference agencies who may use it to perform credit reporting and affordability checks for us and to verify your identity (e.g. age and residence), and to prevent and detect criminal activity, fraud and money laundering and
- To fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, and
- To our agents, advisers or outsource providers in order to provide agreed products or services.
International transfer of information
We may transfer your personal information to recipients (including affiliates of Hermes GPE) located in countries outside of the European Economic Area (‘EEA’) including in USA, Singapore, Channel Islands, Cayman Islands, Mauritius, and Australia. In those instances we will take all necessary steps to protect your personal information in accordance with applicable data privacy laws.
Under applicable EU data privacy laws, you may have a right to:
- Request access to and rectification or erasure of your personal information
- Obtain restriction of processing or to object to processing of your personal information, and
- Data portability (i.e. to request the transfer of personal information from one data controller to another in certain circumstances).
If you wish to exercise any of these rights you should contact the Hermes Information Protection Coordinator as described below. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority.
As a representative of a client, we may contact you occasionally to inform you of products and services we and other members of Hermes Investment Management provide. We will also respond to enquiries for the request of information.
When visiting our website, we collect information about you using cookies in order to process your visit, remember your preferences, increase security and analytics on how a visitor uses the website. Please refer to our cookies notice for further details.
Security and data retention
Hermes GPE strives to maintain the reliability, accuracy and completeness of all personal information it holds to protect privacy and security at all times. The security measures in place on our websites and computer systems aim to prevent the loss or misuse of the information we hold including 3rd parties.
We update and test our security and technology on an ongoing basis. Access to personal information is restricted to those employees responsible for providing benefits or services to you. Employees at Hermes GPE are regularly trained on the importance of confidentiality and keeping your information is kept private and secure.
Subject at all times to applicable laws, we will retain your personal information for a period up to seven years from the end of the relationship.
Changes to this privacy notice
We may revise and/or supplement our privacy notice from time to time to reflect (including but not limited to), any changes in our business, law, regulation, markets and/or the introduction of any new technology.
Enquiries, requests or concerns
All enquiries, requests or concerns regarding this notice or relating to the processing of your personal information, should be sent via email to the Information Protection Coordinator at the international Business of Federated Hermes at InfoProtect@hermes-investment.com
Last updated 10 March 2020