Your Privacy Is Important to Lancaster Private Equity
In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Lancaster Private Equity may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Lancaster Private Equity” refers to The Lancaster Private Equity Group, and its affiliates worldwide.
The Sources of Information
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Lancaster Private Equity during the course of your relationship with us. We may also collect information about your transactions and experiences with Lancaster Private Equity relating to the products and services Lancaster Private Equity provides. In addition, depending on the products or services you require, Lancaster Private Equity may obtain additional information about you, such as your credit history, from consumer reporting agencies.
Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
The Information We Have about You
If you deal with Lancaster Private Equity in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:
- Your name, address and other contact details;
- Your age, occupation and marital status;
- Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
- A head and shoulders photograph from, as applicable, your passport, national identity card or driver's license, as required by laws and regulations addressing due diligence and related matters; and
- A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.
If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:
- Your name and contact details;
- Your role/position/title and area of responsibility; and
Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.
Our Use of Your Personal Information
We may use your personal information to:
- Administer, operate, facilitate and manage your relationship and/or account with Lancaster Private Equity. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
- Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
- Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Lancaster Private Equity; and
- Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
If your relationship with Lancaster Private Equity ends, Lancaster Private Equity will continue to treat your personal information, to the extent we retain it, as described in this policy.
Disclosures of Your Personal Information within Lancaster Private Equity
In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Lancaster Private Equity may be given, or given access to, your personal information. For example, one Lancaster Private Equity entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory and trust services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Lancaster Private Equity is provided below, under Information Security: How We Protect Your Privacy.
Disclosures of Your Personal Information to Third Parties
Lancaster Private Equity does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Lancaster Private Equity, including those that provide professional, legal or accounting advice to Lancaster Private Equity. Non-affiliated companies that assist Lancaster Private Equity in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Lancaster Private Equity dictates.
We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.
You should know that Lancaster Private Equity will not sell your personal information.
Information Security: How We Protect Your Privacy
Lancaster Private Equity is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized Lancaster Private Equity employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:
- The use of specialized technology such as firewalls;
- Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
- Internal and external reviews of our Internet sites and services;
- Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
- Implementing controls to identify, authenticate and authorize access to various systems or sites;
- Protecting information during transmission through various means including, where appropriate, encryption; and
Privacy and the Internet
The following additional information will be of interest to you as a visitor to this site:
- “Cookies” are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements we have placed on other Web sites. For more information about cookies, how our Web sites use them, and your options with respect to their use, please see our cookies policy.
- “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by Lancaster Private Equity itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within Lancaster Private Equity and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a Lancaster Private Equity client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
- When you visit this site, your browser may be momentarily directed to the Web site of an ad server or other third party service provider. This re-direction process will not be apparent to you. These third party Web sites automatically receive your IP address when this happens, and they may also collect information from your interaction with our Web sites including computer and connection information, standard Web log information, and ad information. Such information does not identify you individually.
- Lancaster Private Equity may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.
- Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.
This policy provides a general statement of the ways in which Lancaster Private Equity protects your personal information. You may, however, in connection with specific products or services offered by Lancaster Private Equity, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective January 17, 2018.