Tyndaris

Privacy Notice

Tyndaris LLP, together with its affiliates, (“Tyndaris” or the “Firm”) respects the privacy of every individual whose personal information it handles. Tyndaris collects and processes Personal Data (as defined below) relating to third parties in the course of business. Tyndaris is committed to being transparent about how it handles Personal Data to discharge its data protection obligations.

This privacy notice (the “Notice”) explains how Tyndaris collects, stores and uses, shares and otherwise processes your personal information in connection with your relationship with Tyndaris as an investor in a Tyndaris fund, acting for an investor, or generally being interested in Tyndaris and its services. The Notice is prepared and disclosed in accordance with applicable legislation, including the EU General Data Protection Regulation as amended or supplemented from time to time (“GDPR”), which entered into force on 25 May 2018.

Contact

For all enquiries related to the Notice, please contact Robert Schwartz, Compliance Officer (compliance@tyndaris.com).

Personal Data

The term “Personal Data” as used in this Notice means any information relating to you (i.e. name, contact details, bank account details, photographs). Personal Data does not include anonymised or pseudonymised data. In some circumstances, Tyndaris may anonymise or pseudonymise your Personal Data.

Different rules apply to Personal Data which concerns race, ethnic origin, political opinions or beliefs, religious or other similar beliefs, trade union membership, physical or mental health, sexual life and any offences committed and sentences or court proceedings relating to actual or potential offences and may include photographs in specific circumstances (“Sensitive Personal Data”). Please do not send Sensitive Personal Data to Tyndaris unless it has been specifically requested as generally the Firm does not require it.

Processing

We may process your contact details (address, email address, telephone number) together with any other Personal Data you choose to provide to us, for example if you contact the Firm by letter, telephone, email, or any other means of electronic or personal communication. Tyndaris will process your Personal Data if and to the extent applicable legislation provides a lawful basis for the Firm to do so.

Tyndaris will only process your Personal Data if:

  1. you have consented in writing to the Firm doing so;
  2. Tyndaris needs your Personal Data to perform a contract entered into between you and the Firm;
  3. Tyndaris needs it to comply with a legal obligation;
  4. Tyndaris (or a third party) has a legitimate interest not overridden by your interests, including the providing of investment advisory and/or investment management services by Tyndaris, and administrative, legal, compliance or operational processes within Tyndaris.

Tyndaris uses your Personal Data to deliver investment advisory and/or investment management services to you and/or the institution you work or act for. At your request, and with your consent, Tyndaris may also use your Personal Data to inform you about the Firm’s services.

Tyndaris reserves the right to share your contact details with other companies in the Tyndaris Group. 

Business contact information

If you have had contact with Tyndaris (i.e. at a meeting), the Firm may retain your Personal Data to provide periodic business updates, organise meetings between you and Tyndaris representatives, or for professional communication. 

Supplier / adviser contact information

If you are a supplier or professional adviser to Tyndaris, the Firm stores limited amounts of personal information relating to you, including your name, job title, qualifications, employer organisation, (potential) transactions discussed with Tyndaris and contact details. The Firm stores this personal information for the purposes of administering and maintaining records of services or advice we have received, commissioning further services, and for other purposes of this nature.

Further information

Tyndaris may need to request specific information from you to help the Firm confirm your identity and enable you to exercise your rights under applicable legislation. It is your discretion to provide Personal Data to Tyndaris. If you fail on request to provide Tyndaris with some or all of the Personal Data, the Firm may not be able to provide all or some of the services requested, enter into contracts with you, or send you information. 

Tyndaris may be required to provide supplemental privacy notices on specific occasions when processing your Personal Data. If so, any supplemental notice will explain the purpose for which your Personal Data is being processed.

Transaction information

If you are involved in a transaction that Tyndaris and/or the funds that it manages or advises enters into, or a potential transaction that Tyndaris considers, the Firm may, for KYC purposes, store personal information such as: your CV, previous employment history, financial status and dealings, nationality information (including copies of a passport etc), references provided by third parties, and results of other due diligence carried out. 

This information is collect and stored to:

  • assess and administer actual and/or potential transactions;
  • assess your suitability for involvement in future transactions;
  • comply with our regulatory and legal obligations, including assessing and managing risk;
  • safeguard our legal rights and interests;
  • seek and receive advice from our professional advisors; and
  • provide periodic business updates, as described below.

The personal information we hold about actual and/or potential management teams may be shared with:

  • companies who process personal information on Tyndaris’ behalf and third party outsourced services providers;
  • credit reference agencies;
  • financial intermediaries;
  • professional advisors;
  • other persons who have an interest or involvement in, or who are considering an interest or involvement in, a Tyndaris transaction, for example: co-investors, finance providers and investors in Tyndaris’ funds; and
  • other companies in the Tyndaris group.

In accordance with GDPR, our legal basis for collecting and storing the above-described Personal Data is that its processing is necessary for the Firm’s legitimate interests in running our business. Should Tyndaris enter into a transaction with your involvement, it will also be necessary to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.

Mandatory provision of information

Tyndaris will explain when provision of information is mandatory together with any potential consequences of not providing such information. Tyndaris will only process Personal Data provided to Tyndaris for the purposes listed above.

Retention of personal information

The period for which Tyndaris shall retain Personal Data (and in very limited circumstances, Sensitive Personal Data) shall vary depending on the purposes that it was collected for. However, Tyndaris shall only retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected and processed, including to comply with any applicable law or regulation.

Disclosure

Please note that Tyndaris may use or disclose Personal Data if required to by law, or where the Firm believes that use or disclosure is necessary to protect the Firm’s rights and/or to comply with judicial proceedings or regulatory processes.

Accuracy 

Tyndaris will take all reasonable steps to keep Personal Data accurate and, where required, up to date. If you believe that any of the information about you held by Tyndaris is incorrect please notify the Compliance Officer in writing at compliance@tyndaris.com

Your rights

Individuals whose Personal Data is held by Tyndaris may be entitled to access it, or to request that it is erased, that its processing is restricted, or that any inaccurate personal information is rectified. You may also have the right to object to the processing of your personal information, or in some circumstances to obtain a copy of the personal information in machine readable format. 

Your rights include:
  1. to request access to your Personal Data (via a subject access request) and to request certain information in relation to its processing;
  2. request rectification of your Personal Data;
  3. request the erasure of your Personal Data; or 4. object to the processing of your Personal Data.

Any such request should be submitted in writing to the Compliance Officer at compliance@tyndaris.com.  

You also have the right to make a complaint at any time to the Information Commissioner’s Office (the relevant Supervisory Authority in the United Kingdom for data protection issues (www.ico.org.uk).

Right to Withdraw Consent

If you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. To do so, please write to the Compliance Officer at compliance@tyndaris.com. Once the Compliance Officer receives notification that you have withdrawn your consent, Tyndaris will no longer process your information for the purpose(s) to which you originally consented, unless there are legitimate grounds: (a) for further processing which override your interests, rights and freedoms; or (b) for the establishment, exercise or defence of legal claims.

International data transfers

Tyndaris has operations outside the EEA and as such, in very limited circumstances, your Personal Data may be required to be transferred to and stored at a country outside of your country of residence, including countries outside of the EEA. In the event that Tyndaris transfers personal information to group companies or third parties outside of the EEA, the Firm shall endeavour to ensure that those transfers take place in accordance with applicable legislation, for example by entering into data transfer agreements with the recipient. [Tyndaris LLP has entered into a data sharing agreement with its group companies.] Where data is required to be transferred outside the EEA, safeguards will be applied to such data such that is protected in the same ways as if it had remained in the UK.

Security

Tyndaris will take all reasonable steps to protect the confidentiality and security of your Personal Data but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information online over the Internet and will not hold Tyndaris responsible for any breach of security unless due to Tyndaris’ negligence or wilful default.

Third party websites

Where Tyndaris’ website contains hypertext links to external websites, Tyndaris is not responsible for and accepts no liability in relation to these websites or their contents. You should refer to the applicable privacy policy on any such website.

Changes

Any changes to this Notice will be posted here, so please check on a regular basis when you visit the Tyndaris website.

Authorised and Regulated by the Financial Conduct Authority. Tyndaris LLP is registered in England and Wales at 5 Savile Row, London W1S 3PB. Companies House Number: OC368757. Disclaimer and Regulatory Information | Privacy Notice