Privacy Notice – Personal Data of Clients, Suppliers and Service Providers
This privacy notice explains how Deucalion Aviation Limited, ETG FP Cayman, L.P., and ETG FP Lux SCSp (any/all of these entities, “Deucalion Aviation Group”, “we” or “us”) process personal data of our clients, suppliers or other service providers.
This notice is relevant to you if you are:
- an individual associated with a client, supplier or other service provider or potential client, supplier or other service provider of Deucalion Aviation Group, such as an employee, other representative or beneficial owner of a client, supplier or other service provider; or
- an individual whose personal data are given to Deucalion Aviation Group by a client, supplier or other service provider or potential client, supplier or other service provider, or which we otherwise receive, in the course of our dealings with that client, supplier or other service provider or potential client, supplier or other service provider, or which we received in the context of the acquisition of the aviation investment management and aviation asset management businesses from DVB Bank SE (“DVB”).
This notice provides important information about how we process your personal data, and your data protection rights.
For convenience, in this privacy statement we refer to our client, supplier or other service provider or potential client, supplier or other service provider whom you represent, or with whom you are otherwise associated, as our “Business Partner”.
This privacy notice was last updated on 3 June 2021.
1. Personal data we collect about you
We may collect and process the following personal data about you:
- Personal data that we received in the context of the acquisition of DVB’s aviation investment management and aviation asset management business, for example by way of novation of the respective advisory and management contracts:
- This is personal data that you provided DVB with in the course of the provision of your services to or while otherwise doing business with DVB in relation to the transferred aviation investment management and aviation asset management business. It may include, for example, your name, address, email address and telephone number; information about your business relationship with us; information about your professional role and background; and identification documentation for verification and authorisation purposes.
- The provision of certain of this personal data is necessary for us to provide or receive (or continue providing or receiving) relevant services to/from or otherwise do business with you or our Business Partner.
Personal data that you give us:
- This is personal data about you that you give to us when filling in forms that we (or our Business Partner on our behalf) ask you to complete or corresponding with us by email, telephone, post or otherwise. It may include, for example, your name, address, email address and telephone number; information about your business relationship with us; information about your professional role and background; and identification documentation for verification and authorisation purposes.
- If you do not provide personal data that we request, we may not be able to provide or receive (or continue providing or receiving) relevant services to/from or otherwise do business with you or our Business Partner.
- If you are providing us with personal data about other individuals, such as your colleagues, please inform them of the purpose for which you are providing us the personal data and ensure they are aware of this notice.
Personal data that our systems collect about you:
- If you exchange emails, telephone conversations or other electronic communications with us and our staff members, our information technology systems may record details of those communications, including their content.
- If you visit our websites they will collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and the pages on our site that you visit. Our websites may also download “cookies” to your device as described in our separate cookie statements on our websites if applicable.
- If you do not provide this personal data to us we may not be able to communicate effectively with you.
- Our premises have closed circuit TV systems and building access controls for security and safety purposes which may record you if you visit our premises.
- If you do not provide this personal data to us we may not be able to give you access to our premises.
Other personal data: We may also collect some personal data from the below sources:
- Your colleagues or other business contacts may give us personal data about you, such as your contact details or details of your role in our relationship with our Business Partner. If we need to conduct anti-money-laundering or similar background checks involving you this may require more extensive personal data about you – for example, a copy of your passport.
- We sometimes collect personal data from third party data providers, international sanctions lists, the internet or other publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.
2. Why we process your personal data
We process your personal data, as necessary to pursue our legitimate business and other interests, for the following purposes:
- providing our products and services to our clients, including to ensure that agreements with and instructions from our clients are authorised and validly executed;
- receiving services from our suppliers and other service providers, including to ensure that agreements with and instructions to our suppliers and other service providers are validly executed, including regarding advisory and management contracts novated to Deucalion Aviation Group in the context of the acquisition of DVB’s aviation investment management and aviation asset management business;
- business development (including marketing of our products and services to our clients – we will not send marketing communications to you in your personal capacity) and managing our relationship with our Business Partners;
- assessing and managing the risks facing our businesses, including detecting and preventing fraud and other financial crimes;
- managing and improving our systems and processes, including through monitoring and managing their usage;
- protecting the security and integrity of our premises, information technology systems and information;
- investigating and responding to complaints and other incidents affecting our or our Business Partners’ businesses;
- reorganising or making changes to our business; and
- enforcing and defending our legal rights and those of our Business Partners, staff and affiliates, including potential legal claims or disputes.
We also process your personal data to comply with law and regulation and as necessary to pursue our legitimate interests in directly or indirectly facilitating compliance with the requirements of the law, co-operating with our regulators and other authorities, complying with foreign laws, preventing or detecting financial and other crimes and regulatory breaches, and protecting our businesses and the integrity of the financial markets. This involves processing your personal data for the following purposes:
- carrying out know-your-client (“KYC”), anti-money laundering, anti-terrorism, antimarket-abuse, anti-bribery and corruption, anti-fraud / other financial crime and sanctions compliance activities, including identity checks and background screening;
- monitoring transactions and reporting on them to competent authorities;
- keeping records of communications with our Business Partner, including recording telephone, emails and instant messaging; and
- responding to enquires from, and otherwise co-operating with, regulatory, tax, law enforcement and other governmental agencies, brokers or other intermediaries or counterparties and courts.
3. To whom do we disclose your personal data ?
We will disclose personal data about you, where reasonably necessary for the various purposes set out above, to:
- the direct and indirect shareholders, subsidiaries and other affiliates of Deucalion Aviation Group;
- your colleagues representing our Business Partner;
- counterparty financial institutions, and other persons from whom we receive, or to whom we make, payments, or with whom we conduct other transactions;
- our auditors and our legal, accounting and other professional advisors, so that they can advise us;
- other service providers who hold or process your personal data on our behalf, under strict conditions of confidentiality and security;
- persons who take over our business and assets, or relevant parts of them;
- regulatory, tax, law enforcement or other governmental agencies, courts or litigation counterparties, in any country or territory; and
- other persons where we are required by law to disclose.
These disclosures may involve transferring your personal data abroad. You should be aware that, where our processing of your personal data is subject to EU, UK or Cayman Islands data protection laws, this may include transfers to countries outside the European Economic Area, the United Kingdom or the Cayman Islands (as applicable), which do not have similarly strict data privacy laws, including, for example, the United States of America. In those cases, we will put in place appropriate safeguards such as data transfer agreements based on standard contractual clauses in accordance with article 46(2) of the EU or UK General Data Protection Regulation (as applicable). You may contact us for further information.
4. For how long do we keep your personal data ?
We retain personal data only for as long as reasonably necessary for the purposes described above or as long as required by law or to resolve potential legal claims or disputes.
5. Your data protection rights
This section applies where our processing of your personal data is subject to EU, UK or Cayman Islands data protection laws.
- You have a right of access to the personal data that we hold about you, and to some related information, under the applicable data protection laws. You can also require any inaccurate personal data to be corrected or deleted.
- You can object to us processing your personal data (i) for direct marketing purposes, or (ii) on grounds relating to your particular situation, in case we process your personal data for the purposes of our legitimate interests, at any time.
- You may, in some circumstances, have the right to restrict our processing or obtain the erasure of your personal data.
- You have the right to demand, in some circumstances, certain of your personal data to be transferred to you or a third party.
- To the extent our processing of your personal data is based on your consent, you also have the right to withdraw your consent, without affecting the lawfulness of our processing based on your consent before its withdrawal.
- You further have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
- Exercising any of your rights mentioned above is subject to legal prerequisites and, in certain circumstances, your rights may be limited due to legal exceptions set out, in particular, in articles 17(3) and 22(2) of the UK or EU General Data Protection Regulation or Part 2 of the Cayman Islands Data Protection Act, 2017 (as applicable).
- Please contact us if you wish to exercise any of these rights or should you have any questions relating to your rights or their limitations.
- You can also lodge a complaint about our processing of your personal data with (as applicable) the Information Commissioner, the Cayman Islands Ombudsman or the data protection authority in the place of your habitual residence, place of work or of an alleged infringement of applicable data protection laws.
6. How to contact us
If you have any questions about this privacy notice or our processing of your personal data, or if you wish to exercise your data protection rights, our contact details are below. We are committed to working with you to obtain a fair resolution of any complaint or concerns about privacy.
Deucalion Aviation Group
Tower 42, Level 32,
25 Old Broad Street,
London EC2N 1HQ
Data Protection Contact email@example.com