Compliance

Privacy Policy

Welcome to Paladin Capital Group’s Privacy Policy.

What does this Privacy Policy Cover?

Paladin Capital Group respects your privacy and is committed to protecting our Personal Data. We want to be transparent with you about how we collect and use your Personal Data in making available our website (“Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

  • Who we are and how to contact us.
  • Your rights relating to your Personal Data.
  • Marketing communications preferences.
  • What Personal Data we collect.
  • How we use your Personal Data and why.
  • What happens when you do not provide necessary Personal Data.
  • Personal Data from Third Party Sources.
  • How we use cookies and other tracking or profiling technologies.
  • Who we share your Personal Data with.
  • How we keep your Personal Data secure.
  • How long we store your Personal Data.
  • Our policy on children.

This Privacy Policy aims to give you information on how Paladin Capital Group collects and processes your Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us.

Who we are.

Paladin Capital Group is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either Paladin Capital Group “we”, “us” or “our” in this Privacy Policy).

Our address is: United States:  2020 K Street NW, Suite 620, Washington, DC 20006 and United Kingdom:  20 North Audley Street, London, UK W1K 6WE.

How to contact us.

You can contact Paladin Capital Group by emailing: dpo@paladincapgroup.com.

Our EU representative for Paladin Capital Group’s non-EU entities is: Paladin Capital Group (UK) LLP.  Our EU representative can be contacted directly by emailing them at the following address: dpo@paladincapgroup.com.

Your rights relating to your Personal Data.

If you are based in the EU, in certain circumstances you have the right to:

  • Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Data 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 Data. This enables you to ask us to delete or remove Personal Data 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 Data where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing 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 Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact at dpo@paladincapgroup.com.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at: dpo@paladincapgroup.com.  We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by sending us an email to dpo@paladincapgroup.com.

What Personal Data we collect.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.

Category of Personal Data collected What this means
Identity Data First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data Your home address, work address, billing address, email address and telephone numbers.
Marketing and Communications Data Your preferences in receiving marketing from us and our third parties and your communication preferences.
Technical Data Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.
Finance Data Your bank account details, banking instructions and the funds available to you to invest in our portfolio companies.
Transaction Data Details of investments you have made in our portfolio companies.

 

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, 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 Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data?  In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

  • Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

Generally, we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purpose Category(ies) of Personal Data involved Why do we do this Our legal basis for this use of data
Account Creation ·         Identity Data

·         Contact Data

To register you as a new investor. Contractual Necessity.
To process payments for investments into portfolio companies. ·         Identity Data

·         Contact Data

·         Finance Data

·         Transaction Data

To process and deliver your investment. Contractual Necessity.

 

 

Fraud Prevention ·         Identity Data

·         Contact Data

To keep our website, our services and associated systems operational and secure. Legitimate Interests.

 

We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.

Troubleshooting Technical Data To track issues that might be occurring on our systems. Legitimate Interests.

It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Site and associated systems and services.

Marketing ·         Identity Data

·         Contact Data

·         Marketing and Communications Data

To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. Legitimate Interests.

We have a legitimate interest in providing you with updates on Paladin Capital Group.

 

 

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).

In this case, we may have to stop you using our Site have with us but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third party data source Publicly available? Category(ies) or other types of personal data received.
Social media, e.g., LinkedIn, Twitter, Facebook Yes ·         Identity Data

·         Contact Data

 

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie Purpose
Analytics and Performance Cookies These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site.  The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information.  We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.

 

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here:  https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

 

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

 

Disabling cookies

 

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).  Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com.uk.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

We share your Personal Data within the Paladin Capital Group. This will involve transferring your data outside the European Economic Area (“Europe”).

In addition, many of our external third parties are based outside of Europe so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data outside of Europe, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented

 

Recipients Category(ies) of Personal Data we share. Why we share it Location(s)
Our Affiliates ·         Identity Data

·         Contact Data

·         Technical Data

·         Finance Data

·         Transaction Data

Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc). ·         Within Europe

·         The United States

 

IT Service Providers

 

·         Identity Data

·         Contact Data

·         Technical Data

·         Finance Data

·         Transaction Data

Our service providers provide us with IT and system administration services. ·         Within Europe

·         The United States

 

Financial and legal service providers

 

·         Identity Data

·         Contact Data

·         Transaction Data

Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance and accounting services. ·         Within Europe

·         The United States

HM Revenue & Customs, regulators and other authorities ·         Identity Data

·         Contact Data

·         Transaction Data

Authorities may require reporting of processing activities in certain circumstances ·         Within Europe

 

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data Retention period
Marketing and Communications Data For so long as you remain a customer of ours.
Contact Data For so long as retention is necessary to fulfil the Purposes/Use for which it is used

 

Our policy on children.

This Site is not intended for children below 16 and we do not knowingly collect data relating to such children.

Compliance Statement

Ladies and Gentleman:

Reference is hereby made to the Public Pension Fund Reform Code of Conduct adopted by Paladin Homeland Security Holdings, LLC (together with its subsidiaries and affiliates over which it exercises exclusive control, but excluding any sponsored, managed or advised investment fund or any portfolio company thereof, “Paladin”) on December 10, 2011 (as amended, amended and restated, or supplemented from time to time in accordance with the terms thereof, the “Code”).  Capitalized terms used herein (including in the Exhibits attached hereto) without definition will have the meanings set forth in the Code.

As of the date hereof, to the best of its knowledge after due inquiry, Paladin makes the disclosures set forth in Exhibits A, B and C attached hereto pursuant to the Code and certifies that such disclosures are accurate.

Very truly yours, PALADIN HOMELAND SECURITY HOLDINGS, LLC

By: Mark Maloney, Chief Compliance Officer