Privacy Statement

Athanase Industrial Partner

Athanase Industrial Partners Fund II

Athanase Industrial Partners II AB

together “Athanase

Introduction

Protecting your personal information is important to us.  We have, therefore, created this statement in accordance with the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679 the “GDPR”). GDPR strengthens and unifies data protection across the European Union. It also applies to all organisations that hold or process the personal information of EU-based individuals.

The legislation is intended to ensure that all personal information held by organisations (including, for example, a work email address) which might allow you, as an individual, to be identified, is accurate and secure and there is no mis-use of personal information by that organisation. 

This document sets out how the Athanase collects, uses and safeguards the personal information that you, as an individual, provide to us.

This statement covers all communication with Athanase, including users of Athanase’s websites.

In this privacy statement: “you” or “your” refers to you as an individual and not to any legal entity (such as your employer) which you may be representing by viewing our websites or communicating with us “our”, “ours”, “we” or “us” refers to Athanase.

Please note, if you provide personal information relating to other individuals (for example contact details in a work context), you must either advise those individuals of the details of this statement or provide them with a link or copy of this statement.

By providing your information to Athanase you consent to the collection and use of your personal information in the manner set out below.

The privacy statement covers only Athanase, it does not cover the privacy policies of other entities which may be accessible through, or linked to, any Athanase website or communication.

We will not notify you separately of any changes or updates to this privacy statement, but instead will post them to this page. Any change or update will be effective immediately upon posting.

Should you have any questions on this statement, please email them to dpo[at]athanase.se

Collection of personal data

When you visit an Athanase website or contact an Athanase entity, and when providing any services to you, Athanase may collect personally identifiable information about you from information provided by you. 

This can include the following information relating to you: name, address (residential or corporate), geographical location, email address, contact details, corporate contact information, position.

We may also obtain personal information on you from other public sources.

If you are an investor in a fund managed by a member of the Athanase group, you will be asked for certain personal information to process the subscription and information required for regulatory purposes. These requirements and your rights in relation to the processing of this information will be separately explained in the fund prospectus and application form.

Purposes of Collecting Personal Data

Generally, Athanase will use the personal information provided by you to:

Enable us to act on any agreement with you, your employer or any other relevant third party

Provide information requested by you about the funds we manage for example fund performance, updates or factsheets,

Fulfill legal obligations arising from accounting legislation, funds law, tax legislation and the rules on the prevention, detection and investigation of money laundering,

Respond to queries or provide services to you,

Maintain or update contact data about you or a third party (for example your employer) within Athanase’s systems

Provide to any third parties that may host, maintain or manage services for Athanase, solely to the extent necessary to fulfil their hosting, maintenance or service management functions.

We will never share your personal information with others for marketing purposes, unless you have given us your explicit permission to do so.  Where you have done so, we will only share your information with those service providers that help us manage the activities necessary with conducting business with you or your employer.

Recipients of Data and Transfer of Data

Athanase may disclose personal information to:

Entities within the Athanase group,

Service providers and their respective affiliates engaged by Athanase to process data for the above-mentioned purposes,

Service providers of the funds it manages,

Regulatory authorities, courts and bodies as required by law or to service providers for internal investigations and reporting.

The disclosure of personal information to the third parties set out above may involve the transfer of data other jurisdictions outside the European Economic Area (“EEA”) which may include the United States. Any transmission of personal information by Athanase or its service providers outside the EEA shall be in accordance with the conditions of the GDPR. These countries may not have the same data protection laws that apply in the EEA, but Athanase will authorise its group entities or other service providers to transfer personal information to other countries only where standard contractual clauses or other safeguards permitted under the GDPR have been put in place with parties to whom personal information will be transferred.

Athanase and its service providers apply appropriate information security measures designed to protect personal information in its or its service providers’ possession from unauthorised access by third parties or from any form of computer corruption.

Retention period

Athanase will retain personal information only for as long as required for the purposes set out above. Once the personal information is no longer required, we will take appropriate steps to dispose of any records containing your personal information, to the extent this is operationally feasible and proportionate.

Data subject rights

Where Athanase holds personal information, the owner of that information has the following rights in relation to their personal information unless Athanase is required by law to retain the information:

Right to access any personal data held

Right to have any inaccurate personal data rectified

Right to restrict the use of personal data

Right to request that personal data is erased

Right to object to the processing of personal data

Right to obtain a copy of any personal data held in electronic form (data portability)

Athanase will notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.

You also have the right to lodge a complaint with your local supervisory authority, if you consider that the processing of your personal information by us infringes the data protection legislation.

If your personal information has changed or requires correcting, please let us know by emailing dpo[at]athanase.se so that we can update our records 

Opting out of receiving communications

Athanase and its service providers from time to time send communications, such as fund performance information, manager factsheet, general Athanase updates and event information.

At any time, you can send an email to dpo[at]athanase.se requesting to be removed from some of or all our mailing lists.

Personal data requests

Any questions about our use of your personal information should be directed to Athanase at dpo[at]athanase.se