Privacy Policy

1. How we obtain your personal information

Information you provide to us

You may provide us with personal information via email, post and telephone when you decide to interact with us. This includes contact information, including name, email address and telephone number.  We will only collect and process personal information about you where we have lawful bases to do so (please see section 2 below). We do not knowingly collect or solicit personal information from anyone under the age of 16.

2. Why we use your personal information

We will use the personal information you provide us with for the following purposes, and pursuant to the corresponding legal basis:

Purpose Legal Basis
To provide you with products or services you have requested Contractual necessity
To respond to requests for information submitted by you through our website Legitimate interest
To keep a record of your relationship with us Legitimate interest
To verify your identity Contractual necessity and legitimate interest

Additionally, we will use your personal information to provide you with information and updates on Abry’s active funds, and to keep you informed of our products and services, if you have provided your consent to us doing so, or based on our legitimate interest where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested.

3. Who we share your personal information with

We will share your personal information with third parties as required by law or regulation.  In addition, we will share personal information with regulatory bodies having competent jurisdiction over us, as well as with the tax authorities, auditors and tax advisers, where necessary or as required by law.  We will also share your personal information with affiliates.

We will also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment or other disposition of all or a portion of our business, assets or shares.

4. How we keep your personal information secure

We are committed to protecting the personal information you entrust to us, and to that end we employ robust and appropriate physical, electronic and procedural safeguards to protect your non-public personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

We will keep your personal information only for as long as is reasonably necessary for the purposes set out in section 2 of this privacy policy, unless a longer retention period is required under applicable law.  We will not keep more information than we need for such purposes.  How long we retain your personal information for depends on the purpose(s) for which it is processed by Abry.  For further information regarding how long we will keep your personal information, please contact us using the details outlined at the “How to contact us” section of this privacy policy.

5. Transfer of your personal information

To the extent we transfer your personal information to countries located outside of the European Economic Area (“EEA”), such transfers will be made in accordance with applicable data privacy laws.

6. Your rights

You have the right to access the personal information 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.  We have explained these individual rights and controls below.  To exercise these rights and controls, please contact us at dataprotectionqueries@abry.com.

  • Access: You have the right to ask for a copy of the personal information that Abry holds 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: If there are any inaccuracies in the information we hold about you, please contact us and we will correct them.
  • Deletion: If you think that we shouldn’t be holding or processing your personal information 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 information (other than storing it), if: (i) you are verifying the accuracy of it; (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 are verifying whether our legitimate grounds to process your personal information, override your own rights.
  • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; and/or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer your personal information 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.

7. How to contact us

For any questions regarding Abry’s processing of your personal information (including the rights and controls explained in Section 6 of this privacy policy) please contact dataprotectionqueries@abry.com.

8. Complaints

Should you wish to lodge a complaint with regards to how your personal information has been processed by Abry, please contact your local supervisory authority.  In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/global/contact-us/).

ABRY Partners, LLC, ABRY Partners II, LLC and ABRY UK Ltd) (each an “Abry Entity”, and together “we”, “us”, or “Abry”) treats the privacy of its website users very seriously, and we take appropriate security measures to safeguard your privacy. This policy explains how Abry collects and uses any personal information (i.e., any information that relates to you and that identifies or can be used to identify you (e.g., your name, email, address, or other digital identifiers relating to you, such as IP addresses, cookies or web server logs)) you share with us, including how we collect, process, protect and share personal information.  We reserve the right to change this privacy policy at any time.  We will promptly advise you of any changes to this privacy policy.

The data controllers of your personal information will be each Abry Entity listed in this privacy policy (ABRY UK Ltd having registration no. ZA308415). If you have any questions regarding Abry’s use of your personal information, or this policy, please contact dataprotectionqueries@abry.com.

We rely on various legal bases under applicable data protection legislation in order to process your personal information, including our legitimate interests (e.g., to operate our investment programs), contractual necessity (e.g., to enable us to provide our products and services to you), and as required by applicable law.  Section 2 of this privacy policy explains the applicable legal basis for each purpose for which we process your personal information.

If we require your personal information due to a legal requirement or obligation, or in order for use to perform a contract with you, we will make you aware of this at the time we collect your personal information (unless we are restricted from doing so under applicable law), and the possible consequences of you failing to provide this personal information (e.g., we will 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 products or services to you).