OUR COMMITMENT TO PRIVACY

Your privacy is important to Centurium Capital Management Ltd. and our affiliates (together, “Centurium”, ‘our’, ‘us’ or ‘we’). To better protect your privacy, we are providing information explaining our online information practices.

This Privacy Policy describes how we gather and use information for visitors of this site. Please read this Privacy Policy carefully.

For the purposes of applicable EU laws, Centurium Capital Management Ltd. will be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this Privacy Policy, please contact info@centurium.com.

We rely on various legal bases under applicable data protection legislation in order to process your personal data, including our legitimate interests, contractual necessity and as required by law. We use the personal data we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If we require your personal data due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations). Failure to provide this information means that we cannot provide our services or products to you). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Further information about the legal bases under which we process your personal data is included in the section headed “Why we use your personal data”.

You do not need to take any action as a result of this Privacy Policy, but you do have certain rights as described below in the section headed “Your rights”.

HOW WE OBTAIN YOUR PERSONAL DATA

Information you provide to us

We collect your personal data when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal data via the “Contact us” form on the website or contacting us via email, post and telephone. The personal data we collect about you may include your name, name of your employer address, title, job title, position, telephone number and email address.

Information provided by third parties or publicly available sources

We also process information in relation to companies that we are evaluating in connection with a potential investment in or purchase of such companies. This personal data is obtained via third parties (i.e., the company in question).

WHY WE USE YOUR PERSONAL DATA

To the extent that you provide us with any personal data, through or in connection with this site (i.e., via telephone, email or post), we may use such information for the following purposes:

Purpose	Legal Basis
To provide you with the services or financial products you have requested.	Contractual necessity
To keep a record of your relationship with us.	Legitimate interest
To verify your identity.	Legal requirement and legitimate interest
Fraud and abuse prevention.	Legal requirement and legitimate interest
Litigation management and conducting internal audits and investigations.	Legal requirement and legitimate interest
To administer and protect our business and this website	Legitimate interest
To respond to your contact requests via email, post or telephone.	Legitimate interest

Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal data.

No automated decision making, including profiling, is used when processing your personal data.

DISCLOSURE AND TRANSFER OF PERSONAL DATA

Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our site; any transmission of information or data by you to or through this site is at your sole risk.

Your personal data will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including legal and financial professional advisors, recruitment firms, agents, contractors, and consultants, mailing houses and data hosting providers. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. We also may share your personal data with regulatory authorities. To the extent your personal data is transferred to other countries, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards used, please contact info@centurium.com .

We reserve the right to disclose your personal data as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal data to the new owner of the relevant business and their advisors.

SECURITY AND RETENTION OF PERSONAL DATA

We are committed to protecting the personal data you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will keep your personal data only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal data, please contact info@centurium.com.

CAPACITY

This site is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal data from anyone under the age of 13 without parental consent. If we learn we have collected or received personal data from an individual under the age of 13, we will delete that information.

YOUR RIGHTS

You have the right to access the personal data we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact  info@centurium.com.

• Access: You have the right to ask for a copy of the personal data that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
• Correction: You may notify us of changes to such your personal data if it is inaccurate or it needs to be updated.
• Deletion: If you think that we shouldn’t be holding or processing your personal data any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
• Restrictions on use: You may request that we stop processing your personal data (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal data, override your own rights.
• Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
• Portability: If you wish to transfer your personal data to another organisation (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
• Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal data for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Policy from time to time by updating this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to collect personal data or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. We will use information only in accordance with the Privacy Policy under which the information was collected.

CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact  info@centurium.com .

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal data has been processed by us, please contact your local supervisory authority.