Privacy Notice

WHAT PERSONAL DATA WE MAY PROCESS?

SIA Livonia Partners (Livonia) is an investment advisor of alternative investment fund managers that are investing in companies in the Baltic region. In this privacy notice we define most of the circumstances when we may process personal data of other persons who are not our employees.

The most likely scenarios where Livonia may process any personal data is in the context of our responsibilities for due diligence and later management of target companies that we have selected as candidates for investing and in fulfilment of our know-your-client (KYC), anti-money laundering and any sanctions regimes legal obligations or for personnel recruitment purposes for ourselves or for key positions in our portfolio companies. We may also keep for some time contact details of individuals (managers and shareholders) of target companies with whom we expect to conduct business and relevant information about our business communication with them.

The types of personal data we may process during a due diligence process of a target company may include names, surnames, salary data, work agreements, CVs of management and key employees of the target company.

Legal obligations in the area of anti-money laundering require us as a financial services company to make every effort to verify the identity, suitability and risks involved with setting up and maintaining business relationships with a range of our business partners such as, investors in funds managed by us, business partners from whom an investment (our portfolio company) is acquired or to whom a portfolio company is sold, and other shareholders of the portfolio company. In such cases we process information that may identify our clients or business partners who are natural persons and identifying information of representatives and beneficial owners of our clients or business partners who are natural persons. The types of personal data we may process for KYC purposes are determined by relevant applicable laws and regulations. In addition to identification data, other information may involve such data as information about business operations of our clients and business partners as well as any origin of funds for the transaction.

For recruitment purposes we will process the usual personal and contact information, CVs, and other documents regarding the qualifications and any relevant additional documents that may have been submitted by the applicants themselves.

What are the purposes and legal basis of our data processing?

Purpose for which personal data may be processed

‍(i.e., why we process personal data)

Legal basis for processing personal data

(i.e., the basis in the General Data Protection Regulation on which process personal data)

Selection and due diligence review of suitable target companies for our investments

Our legitimate interests to conduct our business as an investment advisor of alternative investment fund managers

Managing and sale of our investments in portfolio companies in which we made investments

Our legitimate interests to conduct our business as an investment advisor of alternative investment fund managers

Entering into and performing contracts with natural persons (client, business partners, prospective employees)

Taking steps for concluding and performing a contract

Ensuring that content on our website is presented clearly (with the help, among other things, of cookies)

Consent and/or legitimate interests in the smooth and effective operation of the service (see also cookies and similar technology)

Recruitment of qualified personnel for Livonia and/or our portfolio companies

Our legitimate interests to conduct business

Compliance with the relevant laws including legislation on measures to counter money laundering, accountancy law, tax law.

Compliance with our legal obligations under relevant legislation

Your rights

What does this mean?

Right of access

You are entitled to access the personal data we have about you and you can request a copy of it from us. You can usually request a copy at no charge, but if you require multiple copies or ask repeatedly, we reserve the right to charge a fee.

Right to correction

It is important that we should have correct information about you and we advise you to let us know if any of your personal details are incorrect, for example, any qualifications obtained later that maybe added to your CV, if you have consented that we will retain your CV for making any employment offers later on. You can correct information about yourself which is incorrect or incomplete at any time.

Right to deletion

If your personal details are no longer needed for the purpose for which they were gathered, you are entitled to require that they be deleted. In some cases, legal obligation may prevent us from deleting your information immediately. That may involve, for example, obligations under legislation on accountancy, tax or KYC, anti-money laundering laws etc.

Right to restrict

From the moment when you request that we correct your personal data or object to its processing and until we have examined the matter or confirm that your personal data are correct (or have changed them in accordance with your instructions)you will be entitled to restricted processing. That means that (with the exception of storage) we shall only be entitled to process your personal details with your consent, if it is necessary with reference to legal claims, in order to protect rights of third parties or there is a significant public interest in processing it. You are also entitled to request that we restrict the processing of your personal data if the processing is unlawful but you do not want us to delete the personal data.

Right to object

You retain the entitlement to object how and when we process your personal data. In that event we only have the right to continue processing your personal data if we can show compelling reasons which outweigh your own interests, rights and freedoms. However, we are at all times entitled to process your personal details if it is necessary to establish, exert or defend legitimate claims.

Right of data portability

You are entitled to have personal data which you have submitted to the data controller, and which the data controller processes on the basis of consent or in order to conclude and/or implement a contract to be moved to another data controller in a structured and machine-readable format, provided data processing is carried out by automated means.

Right to withdraw consent

If we process your personal data based on your documented consent, you have the right to withdraw your consent at any time. The withdrawal will not have any retrospective effect and will not therefore have any impact on processing information which has already taken place.

Right to complain

If you are not satisfied with the way in which we handle your personal data you can contact us by sending e-mail at info@livoniapartners.com. If you are not satisfied with our answer or consider that we are processing your personal data in an illegitimate or unlawful manner you may lodge a complaint with Latvian data supervisory authority Data State Inspectorate (Datu valsts inspekcija) authority at info@dvi.gov.lv.

whom do we may share PERSONAL DATA with?

For us to work effectively we may need to share your personal data with our portfolio companies (in the context of recruitment) and with our sub-contractors (if we receive services from outsourced suppliers, such as, for example, providers of IT services). We will take all reasonable legal, technical and organisational steps to ensure that your information is managed securely and with a suitable level of protection.

If our contractor processes your personal data on behalf of Livonia we will ensure that the contractor has undertaken to process your details in accordance with data protection requirements that apply.

Livonia will also be required to release your personal data to the appropriate and legal authorities, for example, law enforcement authorities, tax administration, if Livonia is obliged to do by law (such as, under anti-money laundering laws) or with your approval and prior consent.

WHERE DO WE PROCESS YOUR PERSONAL DATA?

We generally process personal data within the EU/EEA. If, however, it would be necessary for us to transfer personal data to a country outside the EU/EEA, we shall take all legal, technical and organisational steps to ensure that your information is managed securely and with a suitable level of protection which is comparable with the protection which is offered within the EU/EEA.

HOW LONG SHALL WE KEEP PERSONAL DATA?

We keep personal data for only so long as it is necessary for the purpose for which they were collected (e.g., fulfilment of an agreement, taking decision on investment upon completion of due diligence, management of investments, completion of selection of job applicants, etc.) and for as long their storage is required by law.

If personal data is processed in the context of any contractual relationship, any data storage period may be extended for the statutory period of limitation under applicable law.

If we store personal data to meet legal requirements, such as, in respect of accounting or anti-money laundering measures, the length of storage of personal data will be determined by law.

CONTACTING US

SIA Livonia Partners, registration number 40203280799, legal address at Brīvības iela 46 - 26, Riga, Latvia, LV-1011 is data controller of personal data mentioned in this privacy policy. We are registered with and regulated by the Financial and Capital Markets Commission of Latvia.

If you have any questions about data processing you may call us at +371 67 687 799 or send an e-mail to info@livoniapartners.com.

Privacy Notice

WHAT PERSONAL DATA WE MAY PROCESS?

What are the purposes and legal basis of our data processing?

Your rights

whom do we may share PERSONAL DATA with?

WHERE DO WE PROCESS YOUR PERSONAL DATA?

HOW LONG SHALL WE KEEP PERSONAL DATA?

CONTACTING US

CONTACT

Tallinn

Riga

Vilnius