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Privacy policy:

Scipio Capital understands that being open and transparent about how we manage, use and process your personal data is of the upmost importance. We are committed to protecting your personal data.

How do we ensure your data is protected and what are your rights? Privacy Notice  – whether you’re a client, supplier or business partner this Privacy Notice explains how and why wecollect and use your personal data. It also outlines your rights on how toobtain, review or withdraw your data. We may change this Privacy Notice from time to time. Any such changes will be posted here, and any material changes will be made prominent. We encourage you to review this page from time to time. 

Quicklinks

 1. General 

This Privacy Notice is applicable to the processing of all personal data of Business Contacts of Scipio Capital, B.V. means each individual whose personal data is processed by Scipio Capital in its role as controller. This is when you work at a business partner, a client or supplier of Scipio Capital, when you are a recipient of commercial messages of Scipio Capital or when you have another business relationship with ScipioCapital. This also includes contingent workers, people working at ScipioCapital as consultants or employees of third parties providing services to Scipio Capital. The contact details of Scipio Capitalcan be found at the Scipio Capital website.

2. How do we collect personal data?

We collect yourpersonal data both online and offline. Most commonly, we receive your personaldata.·        
• From your direct interaction with us, for example when you visit ourwebsite or either when we are doing business together.
• From public data sources like sanction lists, trade registers and LinkedIn,for instance where we need such personal data to verify your identity before wedo business with you.

3. Purposes for which Scipio Capital processes your personal data 

Scipio Capital processes your personal data for the purposes as set out below. We also inform you of the legal ground on the basis of which we process your personal data (as required by the EUGeneral Data Protection Regulation). Where we rely on legitimate interest as a legal ground, we will always seek to maintain a balance between our legitimate business interests as described below and your privacy. If Scipio Capital processes personaldata for other purposes than as listed in this Privacy Notice, you will be informed thereof separately where required and consent will be sought if applicable local law so requires.

3.1. Assessment andacceptance of clients, conclusion and execution of agreements with clients, suppliers and business partners. This purpose includes processing of personal data that is necessary in connection with the assessment andacceptance of clients, suppliers and business partners, including confirmingand verifying the identity of relevant Business Contacts (this may involve theuse of a credit reference agency or other third parties) and conducting due diligence and screening against publicly available government and/or law enforcement agency sanctions lists (e.g. for compliance requirements). Thispurpose also includes the processing of personal data necessary to conclude and execute agreements with clients, suppliers and business partners, including required screening activities (e.g. for access to Scipio Capital’ premises orsystems), delivery of client services, and to record and financially settle delivered services and projects to and from Scipio Capital.

• The legal grounds for these processing activities are based on:  
- Capital is subject
  - The fact that the processing is necessary for the performance of a contract to which you are a party;
-   compliance with a legal obligation to which Scipio.
-   our legitimate interest.

3.2. Relationshipmanagement and marketing. This purpose includes processing of personal data that is necessary for activities such as maintaining and promoting contact with every person taking part of this company through any via of communication.

• The legal grounds for these processing activities are:
-  your consent;
-   the fact that the processing is necessary for the performance of a contractt which you are a party;
-   our legitimate interest. 

3.3. Businessprocess execution, internal management and management reporting. This purpose includes processing of personal data that is necessary for the management of company assets, conducting audits and investigations, reviewing and monitoring compliance with internal policies and procedures, finance and accounting, implementing business controls, providing central processing facilities for efficiency purposes and managing mergers, acquisitions and divestitures. 

• The legal grounds for these processing activities are:
-   the fact that the processing is necessary for the performance of a contractto which you are a party;
-   compliance with a legal obligation to which Scipio Capital issubject; 
-   our legitimate interest. 

3.4. Health,safety, security and integrity purposes. This purpose includes the processing of personal data that is necessary for the protection of the rights,interests and assets of Scipio Capital and its employees, clients, suppliers and business partners and activities such as those involving health and safety. It also includes the authentication of client, supplier or business partner status and access rights.

• The legal grounds for these processing activities are:
-   the fact that the processing is necessary for the performance of a contractto which you are a party;
-   compliance with a legal obligation to which Scipio Capital is subject; or
-   our legitimate interest. 

3.5. Compliancewith the law. This purpose includes the processing of personal data that is necessary for the performance of a task carried out to comply with a legal obligation to which Scipio Capital is subject, including the disclosure of personal data to government institutions or supervisory authorities.

• The legal ground for these processing activities is compliance with a legal obligation to which Scipio Capital is subject. 

3.6. Protection ofthe vital interests of Business Contacts. This purpose includes the processing of personal data that is necessary to protect the vital interests of you as our Business Contact.

• The legal ground for these processing activities is protection of the vital interests of an individual.

4. For what period does Scipio retainyour personal data? 

In general, Scipio Capital will retain your personal data for the duration of your business relationship with Scipio Capital (e.g. during the time Scipio Capital services are delivered to your employer and you are our Business Contact) and for thetime it is necessary to keep your personal data after the end of the services. This period will depend on our purpose of use of your personal data. Examples are:

• Where your business contact details are included in our invoices, we will keep your personal data together with our invoices (usually 7 years based on tax legislation).
• Where your business contact details are included in our project plans, wewill retain your personal data in accordance with our project plan retention periods (usually 10 years depending on the project).
•Where we need your personal data for identification and screening purposes,we will keep your personal data for as long as we are required to keep proof of the screening based on local law.
• If you are one of our prospects, we will keep your contact details during the time that Scipio Capital sends you commercial messages you are interestedin (such as newsletters) and 24 months thereafter. 

Scipio Capital will deviate from these retention periods if Scipio Capital has a pressing interest to keep your personal data longer (e.g. in case of ongoing or expected litigation).

5. Personal data access and transfer

5.1. Access to your personal data is only authorized to the extent such access is necessary to serve the intended purpose and for the respective staff to perform their job. Staff that are authorized to access your personal data may include your Scipio Capital point of contact, and Scipio Capital personnel such as within Finance, Reporting, Internal Audit, IT, marketing and Legal.
5.2. From time to time, Scipio Capital may need to make personal data available to unaffiliated third parties, such asservice providers (companies that provide products and services to Scipio Capital such as payment providers, IT systems suppliers), professional advisors (such as accountants, auditors, or lawyers), public and governmental authorities (entities that regulate or have jurisdiction over Scipio Capitalsuch as regulatory authorities, law enforcement, public bodies and judicial bodies), or in the context of corporate transactions (in connection with any proposed or actual reorganization, merger or sale). Scipio Capital will put in place agreements with third party service providers and professional advisors to protect your data protection interests.
5.3. Due to the global nature of ScipioCapital’ operations, Scipio Capital may need to disclose personal data to its own personnel and departments in other countries. Some of the unaffiliated third parties may also be located outside of your home jurisdiction. Where such international data transfer takes place to a country that has a different data protection regime, Scipio Capital will ensure that the international data transfer will not negatively affect the level of protection of your personal data. Where required, Scipio Capital will inform you of any additional details on the international data transfer.
5.4. In case the recipient of the personal data is based outside the European Economic Area to a country that is not considered to have a level of data protection adequate to the EU, ScipioCapital will ensure that this transfer is based on appropriate safeguards including EU Model Clauses or Binding Corporate Rules. Information on such safeguards can be obtained via the Scipio Capital Privacy Officers at info@scipioholding.com.

6. Security 

Scipio Capital will take appropriate technical, physical and organizational measures to protect personal data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure acquisition or access, that are consistent with applicable privacy and data security laws and regulations. This will include requiring service providers to use appropriate measures to protect the confidentiality and security of personal data.

7. Individual rights and complaints

7.1. Where your personal data are incorrect or incomplete, you always have the right to have your personal data rectified or completed by Scipio Capital.
7.2. Certain local laws grant you theright of access and deletion of personal data, objection to processing of personal data, restriction of processing of personal data, the right to withdraw consent and the right of data portability. Contact your local Privacy Officer to asses if you have these rights based on local laws or regulations.

What are these rights?
7.3. The right of access means that you have the right to request an overview of your personal data processed by or on behalf of Scipio Capital. The rights of deletion and restriction imply that ifyour personal data is not processed in compliance with applicable law, you have the right to have this personal data deleted or restricted (as appropriate). The right to object means you can object to processing of your personal data(as appropriate).
7.4. The right of data portability meansthat a copy of your personal data provided by you to Scipio Capital will, atyour request, be transferred to you in a common machine-readable format or transmitted to a third party without hindrance.
7.5. The right of withdrawal means thatif the processing of your personal data was based on consent, you have theright to withdraw such consent. Such withdrawal will not affect the lawfulness of the processing based on consent before the withdrawal. You can manage your subscription settings via our subscription website.
7.6. You can exercise your rights orfile a complaint by contacting the Privacy Officer at info@scipioholding.com. Scipio Capital will perform your request in accordance with local law as applicable to you.
7.7. For data protection or privacy related complaints, you also have the right to file a complaint with the applicable supervisory authority. 

Scipio HOLDING

Contact Us:

For privacy related queries incl. rectification requests, access requests and complaints please contact info@scipioholding.com. For all other queries please click here

Acquisitions

Manuel
Pintado

Spain

Christopher Bates and
Gabriel Gabriel Gigord

France

Martin
Kominek

Czech Republic

Enrique
Sales

Spain

Pedro Sánchez de
Alba

Spain

Chai Rachabattuni and
Orlando Guerra

Australia

Rafaël
Dufour

France