Privacy Policy

Who we are

Strattam Capital Management, LLC (“Strattam”) respects your privacy and is committed to protecting your personal information. This privacy notice will discuss how we look after your personal information, your privacy rights and how the law protects you.

This privacy notice is provided below. Alternatively, you can download a pdf version of Strattam’s full privacy notice via the investor portal on https://strattam.com.

1. IMPORTANT INFORMATION

Strattam respects your privacy and is committed to protecting your personal information.

This privacy notice describes how we collect and use personal information about you during and after your relationship with us, in accordance with the European Union’s General Data Protection Regulation (GDPR).

It applies to Strattam’s business contacts, suppliers and professional advisors, parties with whom Strattam conducts business (including clients, counterparties and potential clients and counterparties) and investors and any associated individuals. This website is not intended for children and we do not knowingly collect data relating to children.

This privacy notice is issued on behalf of Strattam and its affiliates, so when we mention “Strattam”, “we”, “us” or “our” in this privacy notice, we are referring to Strattam or the affiliate responsible for processing your data.

Strattam is responsible for this website. For the purposes of the GDPR, and for European Union (EU) subjects to whom GDPR applies, Strattam is the controller of your personal information. This means that we are responsible for deciding how we hold and use personal information about you. We are required under the GDPR to notify you of the information contained in this privacy notice.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer by email at info@strattam.com or using the contact details for your region set out below.

You have the right to make a complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority, so please contact us in the first instance.

You can contact Strattam’s Data Protection Officer as follows:

• By mail marked for the attention of the Data Protection Officer
• By telephone 512-829-3949

This notice applies to Strattam’s business contacts, suppliers and professional advisors, parties with whom Strattam conducts business (including clients, counterparties and potential clients and counterparties) and investors and any associated individuals. This notice does not form part of any contract of services. We may update this notice at any time.

It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

We reserve the right to update this privacy notice at any time. We may also notify you in other ways from time to time about the processing of your personal information.

2. DATA PROTECTION PRINCIPLES

We will strive to comply with applicable data protection laws. This means that the personal information we hold about you must be:

1. used lawfully, fairly and in a transparent way;
2. collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
3. relevant to the purposes we have told you about and limited only to those purposes;
4. accurate and to the extent appropriate, kept up to date;
5. kept only as long as necessary for the purposes we have told you about; and
6. kept securely.

3. PERSONAL INFORMATION WE HOLD ABOUT YOU, PURPOSES AND LAWFUL BASIS FOR PROCESSING

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

There are more sensitive types of personal data which require a higher level of protection, known as ‘special categories’ of personal data under the GDPR. We do not collect any ‘special categories’ of personal data about you. Nor do we collect any information about criminal convictions and offences unless revealed by due diligence conducted to comply with a legal obligation or given to us in connection with our role, or potential role, as financial adviser in connection with a transaction, in order to comply with a legal obligation.

The legal basis for collecting, using and storing personal information about the categories of individuals below is that such processing is necessary for our legitimate interests in running and promoting our business.

Visitors to Strattam’s website

When you visit our website, the server will record your IP address together with the date, time and duration of your visit. An IP address is a numerical label assigned to each device connected to a computer network that uses the Internet Protocol for communication. In addition to your IP address the following technical information will also be collected: your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit including the full Uniform Resource Locators (URL), clickstream to, through and from the website (including date and time), pages viewed, download errors, page interaction information (such as scrolling clicks) and methods used to browse away from the website.

You are not required to provide any personal information to access public areas of our website.

Visitors to Strattam’s offices

When you visit our offices, we may collect the following personal information about you for the following purposes:

1. images (but not sound or facial recognition) of you in public areas from CCTV footage in line with our legitimate interests (security of the building); and
2. names and dietary preferences for catering purposes in meetings in line with our legitimate interests (respecting visitors’ needs).

Our business contacts

If you have had contact with Strattam, for example through emailing us or meeting a representative of Strattam, we collect, use and store limited amounts of personal information relating to you, such as your name, job title, employer organization and contact details. We also use publicly available information about you or information you have provided us with to add to Strattam’s contact database.

We will collect and store this personal information for the purposes of:

1. maintaining a record of contacts;
2. providing periodic business updates as described below;
3. organizing meetings between you and Strattam representatives; and
4. sending you periodic updates about Strattam’s business, activities and opportunities, in particular, by email and mail; you can opt out of receiving updates at any time by asking your Strattam business contact to remove you from updates.

When relevant, we will share the personal information we hold about business contacts with:

1. companies which process personal information on Strattam’s behalf;
2. professional advisors, such as accountants, lawyers or other consultants;
3. Strattam’s affiliates, including in the United States;
4. Strattam’s auditors; and
5. applicable regulators and other governmental agencies anywhere in the world.

Our suppliers and professional advisers

If you are an individual associated with a supplier to Strattam, or with one of our professional advisers, we will collect, use and store limited amounts of personal information relating to you, including your name, job title, qualifications, employer or parent organization and contact details.

We will collect, use and store this personal information for the purposes of administering and maintaining records of services or advice we have received, and commissioning further services.

The personal information we hold about individuals associated with our suppliers and professional advisers will be shared on an as-needed basis with:

1. companies which process personal information on Strattam’s behalf;
2. professional advisors, such as accountants, lawyers or other consultants;
3. Strattam affiliates, including in the United States;
4. Strattam’s auditors; and
5. applicable regulators and other governmental agencies anywhere in the world.

Parties with whom we conduct business (including clients, counterparties and potential clients and counterparties)

If you are involved in a transaction or potential transaction that Strattam advises on, we collect, use and store personal information relating to you. To the extent appropriate, this includes your business and personal contact details, 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 or government issued identification), references provided by third parties, and results of other due diligence carried out.

We collect, process and store this personal information for the purposes of:

1. conducting “know-your customer” and other due diligence pursuant to applicable anti-money laundering and anti-corruption laws and regulations and Strattam’s related policies and procedures;
2. assessing your suitability as our client, including by verifying your identity;
3. advising on potential transactions;
4. administering any transaction that we enter into;
5. statistical analysis and market research;
6. maintaining records of investments;
7. billing and invoicing purposes;
8. complying with our regulatory and legal obligations, including assessing and managing risk;
9. identifying and preventing fraud and other unlawful activity;
10. safeguarding our legal rights and interests;
11. seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants;
12. organizing and holding meetings and events; and
13. sending you periodic updates about Strattam’s business, activities and opportunities, in particular, by email and post; you can opt out of receiving updates at any time by asking your Strattam contact to remove you from such updates.

The personal information we collect, use and store about individuals associated with our clients, counterparties and potential clients and counterparties with whom we conduct business may be shared with:

1. companies which process personal information on our client’s behalf;
2. credit reference agencies;
3. financial intermediaries;
4. professional advisors, such as accountants, lawyers or other consultants;
5. other persons who have an interest or involvement in, or who are considering an interest or involvement in, a transaction upon which Strattam is advising, including co-investors, other providers of finance and investors in Strattam;
6. Strattam’s and Strattam’s clients auditors; and
7. applicable regulators and other governmental agencies anywhere in the world.

As discussed above, our legal basis for collecting, using and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by advising on potential transactions or investments in our fund investment vehicles. If we advise on a potential transaction or fund investment that you consider entering into, it will also be necessary for us to process your personal information for the purpose of performing in connection with the relevant contract and to comply with our regulatory and legal obligations.

Investors in our Funds

We collect, use and store personal information about investors in our funds for the purposes of:

1. complying with our regulatory and legal obligations;
2. communicating with investors (including the mailing, in physical or electronic format, of Annual Reports, AGM or EGM notices or proxy cards, or communications in relation to other corporate actions);
3. facilitating the payment of subscriptions, redemptions and distributions; and
4. sending you periodic updates about Strattam’s business, activities and opportunities, in particular, by email and mail; you can opt out of receiving updates at any time by asking your Strattam contact to remove you from such updates.

We share the personal information we hold about investors in our funds with:

1. companies which process personal information on Strattam’s behalf;
2. professional advisors, such as accountants, lawyers, proxy advisers or other consultants;
3. other companies in the Strattam group in the United States;
4. Strattam’s auditors; and
5. applicable regulators and other governmental agencies anywhere in the world.

As discussed above, our legal basis for collecting and storing personal information about investors in our funds is that such processing is necessary for our legitimate interests in running and operating our business, and ensuring effective communications with investors.

Lawful basis for using your personal information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances (each a lawful basis):

1. where we need to perform the contract we are about to enter into or have entered into with you;
2. where it is necessary for our legitimate interests (as further explained above) and your interests and fundamental rights do not override those interests; or
3. where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data.

If you fail to provide personal information

If you do not provide certain information when requested, we may not be able to perform the services you requested (such as advising on a particular transaction or making an investment in our fund), or we may be prevented from complying with our legal obligations (such as to perform client and investor due diligence).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

1. DATA SHARING

We share your personal information with third parties only as necessary, including third-party service providers and other entities in Strattam.

We require third parties to respect the security of your personal information and to treat it in accordance with the law.

We transfer your personal information outside the European Economic Area and when we do, you can expect a similar degree of protection in respect of your personal information.

Why do we share your personal information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer our relationship with you or where we have another legitimate interest in doing so. “Third parties” includes third-party service providers (including contractors) and other entities within the Strattam group worldwide.

Which third-party service providers use your personal information?

The following activities are carried out by the following categories of third-party service providers in the following locations:

1. Telephone and video conferencing, including in the United States;
2. Recording emails for compliance purposes, including in the United States;
3. Contact database management;
4. Hosting and/or participating in investor data rooms by various providers, including in the United States;
5. Marketing communications, by Strattam in the United States;
6. Research services for investor or client management, including in the United States;
7. Communications, including in the United States; and
8. Meeting catering purposes.

How secure is your personal information with third-party service providers and other entities in our group?

All our third-party service providers and other companies selected by Strattam are required to take appropriate security measures to protect your personal information in line with the GDPR. Except where needed for their own direct relationship with you, we do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

When do we share your personal information with other entities in Strattam?

We will share your personal information with other companies in Strattam for internal administrative purposes.

When do we share your personal information with any other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. If needed to comply with law and regulations, we will also need to share your personal information with a regulator, governmental agency or otherwise.

Transferring your personal information outside Europe

We share your personal data within Strattam’s organization and with service providers. This will involve transferring your data outside the European Economic Area (EEA).

Many of our third-party service providers are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

1. We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission
2. We use specific contracts approved by the European Commission which give personal information the same protection it has in Europe.
3. Where we use third-party service providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5. DATA SECURITY

We have put in place appropriate measures to protect the security of your personal information.

Third parties will only process your personal information where they have agreed to treat the personal information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to access it. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

6. DATA RETENTION

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, regulatory or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal or regulatory retention requirements.

In some circumstances we may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a business contact, supplier, professional advisor, counterparty with whom Strattam conducts business (including client) or an investor of Strattam’s funds we will retain and securely destroy your personal information in accordance with our data retention policy and as required by application legal and/or regulatory requirements.

7. YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights in connection with your personal information

Under certain circumstances, under the GDPR you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below), subject to legal and/or regulatory requirements that we retain it for a specific period of time.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Your right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.