Privacy Policy

6. Your Personal Data & Our Purposes & Lawful Basis For Using It

We will only Use your Personal Data when the Data Protection Laws and other applicable laws and regulations allow or require us to so.

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Most commonly, we will Use your Personal Data in the following circumstances, each of which is a legal basis:

• Where we need to perform the contract we are about to enter into or have entered into with you;

• Where it is necessary for our legitimate interests, as explained in the sections below that may apply to you, and your interests and fundamental rights do not override those interests; or

• Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent alone as a legal basis for Using your Personal Data. Please note that, subject to the Data Protection Laws, we may Use your personal information without your knowledge or consent, in compliance with this Privacy Policy, where such Use is required or permitted by applicable law or regulation.

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If you fail or decline to provide certain Personal Data which we may request from you, we may not be able to perform any contract we have entered into with you, or we may be unable to deal with you in such other capacity as may apply to you.

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We will only Use your Personal Data for the purposes which we have described in this Privacy Policy, or as otherwise permitted by the Data Protection Laws, unless we reasonably consider that we need to use it for another reason and that reason is not incompatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will use our commercially reasonable efforts to notify you and explain the legal basis which allows us to do so.

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As discussed below, Falcon House may Use your Personal Data in different ways depending on the ways in which you interact with us and your relationship with us. Please note that you and your Personal Data may be covered by more than one of the following categories depending on the different ways in which you interact with us and your relationship with us over time.

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Visitors to Falcon House’s Site

When you visit our Site, we may Use your Personal Data through automated means.

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For example, we may collect your IP address each time you request a page during a visit to the Site; an IP address is often associated with the portal through which you enter the Internet. At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. We may also collect geolocation data (e.g., your physical location) when you visit our Site to the extent that the device on which you are visiting our Site provides such data.

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The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users to determine whether such users have opened those e-mails or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that constitutes Personal Data.

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During some visits to the Site, we may use software tools such as web beacons or JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our Site, and, subject to the Data Protection Laws, for any other purpose to the extent permitted by applicable law.

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If you wish to contact us using the Contact Us page our Site, you will need to provide your name and contact details so that we may accurately record your message, including for legal and compliance purposes in accordance with our applicable policies, and respond to your message.

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Our legal basis for Using Personal Data about visitors to our Site is that such Use is necessary for our legitimate interests in maintaining, updating, and securing our Site, and in undertaking business development and promotion.

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Please note that our Site may provide links to third-party websites for your convenience and information. Such third-party websites operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. Falcon House is not responsible for the privacy practices of such third-party websites.

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Please also see Section 7 (Cookies & Digital Advertising) below.

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Visitors to Falcon House’s Offices & Events

When you visit our offices or attend events organized by us, we may Use the following Personal Data about you for the following purposes:

• Contact information from security lists of visitors to our offices or events in line with our legitimate interest in the security of our offices and events;

• Video images of you in the entry and exit areas of our offices or events from CCTV footage in line with our legitimate interest in the security of our offices and events;

• Audio, video, or still photos of you at our meetings or events, which may include meetings events held in our offices or online, in line with our legitimate interests in memorializing such meetings or events and for publicity, marketing, and public relations purposes;

• Your name and time of entry into and exit from our offices, meetings, or events through a security access system in line with our legitimate interest in the security of our offices and events;

• Your name and dietary preferences for catering purposes in meetings in our offices or at events in line with our legitimate interest in respecting your dietary needs;

• Limited health data to assist in the control of infectious diseases, e.g., Covid-19, in line with our legitimate interest in protecting the health of our staff, visitor, and guests and our legal obligations for health and safety;

• If applicable, health information from completion of an accident log in order to comply with our legal obligations for health and safety; and

• Your name, organization, and contact information for the purpose of organizing meetings and events, including meetings and events held in our offices, and providing, e.g., name badges, attendee lists, team lists, and table plans.

 

We may share the Personal Data we have about visitors to our offices or attendees at our events with:

• Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, security, legal, accountancy, data, marketing, event management, and catering services;

• Professional advisors, including accountants, lawyers, or other consultants;

• Other companies in the Falcon House Group;

• Auditors of companies in the Falcon House Group; and

• Applicable regulators and other governmental agencies anywhere in the world.

 

Please note that when you visit our offices or attend our events, various third parties, including the management of the buildings in which our offices are located or of the venues in which our events are held, may, independently of and separately from Falcon House and any Personal Data we may share with them in accordance with this Privacy Policy, collect and use your Personal Data for their own purposes, including security, event management, and publicity. Any such third party acts as the controller of your Personal Data for such purposes and so are subject to a separate privacy notice which you should obtain from them. Falcon House is not responsible for the privacy practices of such third parties.

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Individuals With Whom Falcon House Has Contact for Business Purposes

If you have contact with Falcon House, for example through emailing or meeting a representative of Falcon House, we may Use your Personal Data, such as your name, job title, organization, and contact details.

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We may your Use Personal Data that is publicly available, including biographical information or information about your background and professional experience, or which you have provided us to add to Falcon House’s contacts directory. Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you. We will use this Personal Data for the purposes of:

• Maintaining a directory of contacts;

• Organizing meetings between you and Falcon House’s representatives;

• Keeping records of our relationship and communications with you;

• General business marketing, including reporting on macro trends and other business and economic insights;

• Sending you periodic updates about Falcon House’s business, events, presentations, and opportunities, including by email and post; you can opt out of receiving such updates at any time by contacting us via one of the methods set-out in Section 13 below or via the Contact Us page on our Site, by asking your Falcon House business contact, or, if applicable, by clicking the “Unsubscribe” link in an email you receive from us.

 

We may share the Personal Data we have about our business contacts with:

• Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, security, legal, accountancy, data, marketing, and catering services;

• Professional advisors, including accountants, lawyers, or other consultants;

• Other companies in the Falcon House Group;

• Auditors of companies in the Falcon House Group; and

• Applicable regulators and other governmental agencies anywhere in the world.

 

Our legal basis for Using Personal Data about business contacts is that such Use is necessary for our legitimate interests in undertaking business development and promotion.

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Individuals Who Are or Who Are Associated with Falcon House’s Suppliers, Vendors, or Professional Advisors

If you, or a company with which you are associated as an employee or otherwise, is a supplier, vendor, or professional advisor to Falcon House, we may Use your Personal Data, such as your name, job title, qualifications, organization, and contact details.

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We may your Use Personal Data that is publicly available, including biographical information or information about your background and experience, or which you have provided us, for the purpose of conducting anti-money laundering checks, administering and maintaining records of goods, services, or advice we have received, and commissioning further services or procuring further goods. Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you, in order to document and keep records of our relationships with our suppliers, vendors, and professional advisors.

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We may share the Personal Data we have about our suppliers, vendors, and professional advisors with:

• Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services;

• Professional advisors, including accountants, lawyers, or other consultants;

• Other companies in the Falcon House Group;

• Auditors of companies in the Falcon House Group; and

• Applicable regulators and other governmental agencies anywhere in the world.

 

Our legal basis for Using Personal Data about individuals who are, or who are associated with, our suppliers, vendors, or professional advisors is that such Use is necessary for our legitimate interests in operating our businesses.

Individuals Who Are Involved In Transactions Or Potential Transactions With Falcon House

If you, or a company with which you are associated as an employee or otherwise, is involved in a transaction relating to Falcon House’s business, including as a potential investor in a private fund that is part of the Falcon House Group, we may Use your Personal Data.

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To the extent applicable, such Personal Data may include your business and personal contact details, interests or marketing preferences, professional opinions and judgements, visual images and photographs required for business purposes, log-in details for user accounts, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may carry out in accordance with our policies, legal or regulatory requirements, or other reasonable business practice. Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you. We may also make inferences about you from your Personal Data, for example regarding your investment interests and preferences.

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We may Use such Personal Data for the purposes of:

• Performing conflict checks;

• Verifying the identify of individuals;

• Undertaking due diligence and performing background checks;

• Conducting anti-money laundering checks;

• Evaluating potential transactions;

• Maintaining records of investments;

• Trade and transaction reporting;

• Administering transactions that are entered into;

• Statistical analysis and market research;

• Keeping records of our relationship and communications with you;

• Maintaining records of investments and potential investments;

• Billing and invoicing purposes;

• Complying with our regulatory and legal obligations, including assessing and managing risks;

• Identifying, preventing, and reporting fraud, money laundering, tax evasion, and other unlawful activity;

• Safeguarding our legal rights and interests;

• Seeking and receiving advice from our professional advisors, including accountants, lawyers, and other consultants;

• Organizing and holding meetings and events;

• Marketing of investment products;

• General business marketing, including reporting on macro trends and other business and economic insights; and

• Sending you periodic updates about Falcon House’s business, events, presentations, and opportunities, including by email and post; you can opt out of receiving such updates at any time by contacting us via one of the methods set-out in Section 13 below, via the Contact Us page on our Site, by asking your Falcon House business contact, or, if applicable, by clicking the “Unsubscribe” link in an email you receive from us.

 

We may share the Personal Data we have about counter-parties with whom we may, or may explore, conducting business with:

• Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services;

• Credit reference agencies;

• Financial intermediaries;

• Background verification or private investigative services, or other risk management services;

• Other persons who have an interest or involvement in, or are considering an interest or involvement in a transaction in which Falcon House is involved, including co-investors, other providers of financing, and investors in certain private funds that form a part of the Falcon House Group;

• Professional advisors, including accountants, lawyers, or other consultants;

• Other companies in the Falcon House Group;

• Auditors of companies in the Falcon House Group; and

• Applicable regulators and other governmental agencies anywhere in the world.

 

Our legal basis for Using Personal Data about counter-parties with whom we may, or may explore, conducting business with is that such Use is necessary for our legitimate interest in running our business, including by advising on potential transactions. If we enter into a transaction that you are, or a company with which you are associated is, involved in, we will also need to Use your information for the purpose of completing such transaction and complying with our regulatory and legal obligations.

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Individuals with Whom Falcon House Has Contact During a Recruitment Process

We may Use Personal Data about candidates during the application and recruitment process, including Personal Data provided by candidates, from third parties, including recruitment agencies, job sites, former employers, and background verification services, and Personal Data which is publicly available, including from professional networking sites, social media, blogs, and other online or digital sources.

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We may Use the following Personal Data about candidates:

• Personal contact details such as name, title, addresses, telephone numbers, and personal email address;

• Date of birth;

• Nationality;

• Current salary, bonus, annual leave, pension, and benefits information;

• Current notice period;

• Desired start date with Falcon House;

• Desired location of employment or workplace;

• Passport number and driver’s license;

• Recruitment information, including copies of right to work documentation, references, and other information included in a CV or cover letter as part of the application process;

• Employment records, including job titles, responsibilities, work history, working hours, language capabilities, training records, appraisal and fitness and propriety records, and professional memberships;

• Compensation history; and

• Audio, video, or still photographs required for business purposes.

 

Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you.

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We will Use your Personal Data to:

• Evaluate your qualifications for and suitability as a candidate for employment with Falcon House;

• Arrange interviews, meetings, tests, or events in connection with the recruitment process;

• Verify your education and work history, professional licenses or memberships, and fitness and propriety;

• Keep records of our relationship and communications with you; and

• Take other necessary steps prior into entering into an employment or other contractual arrangement with you.

 

In connection with the recruitment process, we may share the Personal Data we have about candidates with:

• Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services;

• Background verification services;

• Professional advisors, including accountants, lawyers, or other consultants;

• Other companies in the Falcon House Group;

• Auditors of companies in the Falcon House Group; and

• Applicable regulators and other governmental agencies anywhere in the world.

 

Should you be successful in your application, we will only transfer Personal Data to your employment record if it is relevant to your ongoing working relationship with Falcon House.

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Should you be unsuccessful in your application, we will destroy or delete your application details but will keep on file your name, any additional identifiers needed to distinguish you from candidates with the same name, your contact details, and the position for which you applied for future recruitment purposes, unless you specifically request this should not be the case.

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Where legally permissible, we may also ask you to voluntarily provide additional Personal Data, including regarding your gender, race/ethnicity, disability status, or status as a veteran. Falcon House will not consider either this information or your choice to provide it in evaluating your qualifications for employment with us. This Personal Data will be Used only for legal and compliance purposes and only shared in accordance with applicable law or regulations.

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Our legal basis for Using Personal Data about candidates for employment with us is that such Use is necessary for our legitimate interests in operating our businesses, including our legitimate interest in attracting and retaining the qualified personnel necessary to operate our business.

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Once you are no longer a candidate for employment with Falcon House, we will not keep any Personal Data about you for any longer than is necessary for the purposes for which we need to Use such Personal Data and will destroy or delete such Personal Data after such time.

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Please note that third-party recruitment agencies or job sites which collect and use your Personal Data, including for the purpose of introducing you as a candidate at Falcon House, act as the controller of your Personal Data for that purpose and so are subject to a separate privacy notice you should obtain from them. Falcon House is not responsible for the privacy practices of such third parties.