Dee4 Capital Partners ApS– Policy for data privacy
This policy for data privacy explains how Dee 4 Capital Partners ApS (“we”, “us”) processes (e.g. collect, use, share and otherwise process) your personal information. As a data controller, we are required to protect your personal information, and our aim is to make you feel secure when we process your personal data as we recognize and respect the importance of your privacy. We will process any personal information about you in accordance with this policy, as well as applicable law.
When do we process data?
In the course of our business, we register and use information about you (personal data), when you interact with us as an individual or an indivdual who is connected with an investor or a business partner of ours. You could be an authorised signatory, a beneficial owner, a director, an employee, or a third party connected to one of our investors or business partners. We may process your personal data for any of the following purposes, depending on the capacity in which you interact with us:
- Meeting our obligations and providing services to our investors and business partners
- Complying with applicable law, including anti-money laundering legislation
- For administrative purposes, including to secure and maintain our internal systems
- Carrying out controls to prevent fraud and financial crime
- Managing the relationship to our investors and business partners, including marketing of services
- Recruitment processes.
We will only register and process your personal data if we have a legal basis to do so. This means that we register and use personal data when:
- You have made, or you are considering making an agreement with us
- You have granted us consent to use your personal data for a specific purpose
- We have to comply with certain legal obligations in accordance with
- The Danish Anti-Money Laundering Act
- The Danish Tax Control Act
- The Danish Bookkeeping Act
- The Danish Alternative Investment Fund Managers Act
- The Danish Data Protection Act
- We or the investor or business partner that you have a connection with pursue a legitimate interest. This could be when we or the customer have a business or commercial reason, such as administrate the services that the investor has requested, to use your personal data, need to prevent abuse and loss, or want to use it for marketing purposes. We will only do so if our interest clearly outweighs your interest in not having your personal data processed by us.
What personal data do we register and use?
We typically process the following types of personal data:
- Basic personal information, for instance your name, address, contact information, country of residence, education and occupation.
- Identification documentation, for example a photocopy of your passport, driving licence, or other documentation required by law.
- Information about your criminal record, for recruitment purposes.
- Resume and references, for recruitment purposes.
How long do we store your personal data?
Basic personal information and identification documents
We keep your data only for as long as it is needed for the purpose for which your data were registered and used. Therefore, we keep your information as long as we are providing a service to you. When your business connection with us has terminated we normally keep your data for a further 5 years. This is primarily due to our obligations under the Bookkeeping Act, the Anti-Money Laundering Act and requirements from the Financial Supervisory Authority.
Information about criminal record
We obtain your criminal record for recruitment purposes, when hiring new employees. We immediately delete your criminal record, when the recruitment process is finished.
Personal data for recruitment purposes
Resumés and references are received in two cases:
- When applicants apply for a specific job posting.
- When applicants apply for a non-specific job posting.
When an applicant applies for a specific job posting, and the job applicant is offered a job, we delete the resume and reference immediately after the applicant is hired.
When an applicant applies for a specific or a non-specific job posting, and the applicant is not offered a position, we ask for the applicant’s consent to store the data for future relevant job postings, if we consider the applicant’s profile relevant. If the applicant consents, we store the data for up to 6 months. If the applicant does not consent, we immediately delete the resume and references.
Third parties and personal data
Personal data from third parties
We register and use data from third parties, for instance:
- The Danish Business Authority and other publicly accessible sources and registers. We register and use the data they have about you to check that the data you have provided to us is accurate
- Publicly accessible databases providing data and information within private equity (Funds and fundraising, performance, fund managers, institutional investors and deals)
Which third parties do we share your personal data with?
In some cases, we may share personal data with third parties.
- We disclose personal data to public authorities as required by law, including the State Prosecutor for Serious Economic and International Crime (SØIK) in accordance with the Danish Anti-Money Laundering Act, the Danish tax authorities (SKAT) in accordance with the Danish Tax Control Act, the depositary of the managed alternative investment fund and the Danish Financial Supervisory Authority (Finanstilsynet) for various purposes.
- For the performance of a contract, with your consent or if we are allowed by law, we may disclose data to external business partners (e.g. banks and external advisors).
- In connection with IT development, hosting and support, we transfer personal data to data processors, within the EU and the EEA.
What are your rights?
You have the following rights:
- You have the right to request access to and rectification or erasure of your personal data.
- You also have the right to object to the processing of your personal data and have the processing of your personal data restricted
- If processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent.
- You have the right to receive your personal information in a structured, commonly used and machine-readable format (data portability).
- If you are dissatisfied with how we register and use your personal data and your dialogue with us has not led to a satisfactory outcome you can lodge a complaint with the Danish Data Protection Agency at qg@qngngvyflarg.qx (Datatilsynet, Borgergade 28, 5., 1300 Copenhagen K, Denmark)
There may be conditions to or limitations in your rights. Therefore you may not e.g. in all cases have the right of data portability. Your rights depend on the specific circumstances of the processing activity.
You are always welcome to contact us if you have any questions about your privacy rights and how we register and use your personal data. You can contact the Data Protection Officer (DPO) of Dee4 Capital Partners via email at serqqvr.yrr@qrr4pncvgny.pbz. Copenhagen, August 2019
