Privacy Notice

Hg respects your privacy and recognises the importance of protecting the personal information that we hold.

This statement sets out the rights that you have in respect of your personal information. It also details examples of when we collect personal information, what personal information we collect, what purposes we use that information for, who we share that information with and how long we hold certain personal information for.

This Policy applies to actual and potential investors, consultants, suppliers, advisers, business partners and associates, recruitment candidates and visitors to our office, events and website.

Hg may change this Policy over time by updating this page. You can determine if the Policy has been revised since your last visit by referring to the “last updated” date at the bottom of the page.

This privacy statement was updated on 21 February 2020.

Hg collects information from or about you, e.g. when:

you are an actual or potential investor, consultant, supplier, advisor or business partner or associate;

you are a business owner, entrepreneurial leader or talented individual who is or may be interested in the work we do or the opportunities we provide;

you visit our website, sign up to our news notifications via any registration form on our website, or you engage with us on social media;

you contact us by any means with queries, interests or concerns or complete surveys we send you;

you have an appointment with us or have or will attend an event of ours, including one of our forums or networking dinners;

you visit one of our offices which have CCTV systems which record your image and operated for the security of both visitors and staff; and / or

you choose to provide us with your personal information during business encounters, for example in the form of a business card.

Hg may collect personal information from you directly, from public sources or from third parties, such as business associates or recruitment agents.

The type of personal information that Hg collects depends on the legitimate purposes for which it is collected (see 2.3 below) but may include:

names, email addresses, phone numbers, job titles, places of work, work addresses, photos, career biographies, dietary requirements;

if you are an actual or potential investor, consultant, supplier, adviser or business partner, information required to verify your identity, including passports, identification documents and proof of home addresses for Know Your Customer, anti-money laundering, references, background checks and other similar checks;

any personal information that is contained in consultancy agreements, engagement letters or other forms of written or oral agreements; and/or

information gathered in relation to a recruitment opportunity, including your CV, which we may have received directly from you (e.g. via the email address [email protected]), or, with your consent, from Hg staff or a third-party.

We collect and use your information on the basis that:

it is in our or others’ legitimate interests to do so (as described below), and such interests are not overridden by your privacy interests;

it is reasonably necessary to meet our legal or regulatory responsibilities, including our fiduciary duties and FCA obligations to our clients or when we make disclosures to courts, tribunals, authorities, regulators or supervisory or governmental bodies;

in some cases, it is necessary or desirable for us to enter into, and perform our obligations under our contract with you; and/or

we have obtained your consent.

Hg may use your information for the purposes of the following legitimate interests:

compliance with our legal and regulatory obligations, including our fiduciary duties and FCA obligations to our clients; requests for disclosures from a court, tribunal, authority, regulator or supervisory or governmental body; compliance with Know Your Customer and anti-money laundering requirements and references, background and other similar checks on or conducted by Hg;

performing activities relating to client management, financial management, reporting and administration (such as promotion of our business to potential clients, performing accounting, auditing and other internal functions, managing existing investments, and providing updates of investments to clients);

facilitating business opportunities, including communicating with you about potential business, partnership or career opportunities; searching and assessing potential investment and value creation opportunities for Hg and the portfolio companies we manage; conducting market due diligence or other due diligence in respect of potential or actual investment opportunities; discussing merger or acquisitions with a potential buyer or merger partner, including their advisers; administering relationships, meetings and travels for employees, clients, business partners and experts;

recruitment activities, including assessing your application for employment with us or one of our portfolio companies; evaluating potential candidates for recruitment processes;

ensuring our marketing efforts and publications are appropriately focused, including communicating with you about service updates, marketing and promotions based on your communication preferences; responding to your enquiries and resolving your complaints; and improving our marketing materials to tailor their relevance to those visiting our website and social media channels; and/or

obtaining professional services from our lawyers, accountants, consultants, auditors and other advisers.

If you would like further information on how we have balanced our and others’ legitimate interests against your privacy interests, please contact [email protected]

Hg Group
Hg shares your information within the Hg group, including our portfolio companies (details of which you can find on our website) and in certain circumstances, e.g. in relation to recruitment opportunities, prospective portfolio companies.

Third-party providers
Hg may share your information with third parties, including independent contractors or subcontractors (such as individuals who are engaged to assist Hg or its portfolio companies on specific projects), agents (such as recruitment agents and corporate secretarial services agents) and service providers (such as legal, consultancy, financing and paper archiving providers) who need to receive your information in the course of providing services for or on behalf of us for the purposes specified in this Policy.

Hg also engages trusted third-party IT service and software providers to host, store and process data, e.g. information relating to employees is stored in payroll and HR software systems; information about employment candidates and event attendees is recorded on a CRM system; information relating to our investments and investment activities is retained on accounting and reporting software systems.

Information will only be transferred or provided to third-party providers where reasonably necessary to enable us to fulfil the purposes set out in this Policy.  We will ensure that each such provider has agreed to protect and maintain the confidentiality and security of information Hg shares with them.

Business partners
We may share information with an actual or potential buyer, seller, co-investor or joint venture partner and our and their advisers in connection with any actual or potential acquisition, sale, co-investment, joint venture or similar transactions in connection with Hg and/or the portfolio companies managed and/or invested by Hg.

Authorities as required or permitted by law
We may disclose your personal information: (a) as required or permitted by, or to comply with, applicable law, regulation, court or tribunal processes or other statutory requirements;  (b) respond to requests from or disclosures required by any court, tribunal, authority, regulator or  supervisory or governmental body or (c) to comply with Know Your Customer and anti-money laundering requirements and references, background and other similar checks on or conducted by Hg.

Standard retention period
The personal data we collect will only be retained for as long as it is needed to fulfil the purposes set out in this privacy statement. This period is maximum 10 years, subject to certain variations described below.

Deletions will be carried out in accordance with Hg’s retention policy.  Any information stored in hard copy format (in paper form) is treated as confidential and will be shredded at the point of soft copy deletion.

Variations to retention period
We will retain your information for longer than the standard retention period where permitted or required by law, including to comply with the duration of any statutory or contractual limitation periods. For example, we will retain information about investors for the lifetime of the fund plus an additional seven years.

In relation to data collected about visitors to the website, data is retained for 50 weeks.

In relation to personal data collected about potential candidates for Hg or its portfolio companies who have not been hired by Hg or one of its portfolio companies, data may be retained for up to six years in case such candidates are suitable for other employment opportunities which arise at Hg or across its portfolio.

Data protection laws in some countries provide you with various rights. In particular, in the European Union, data protection laws provide rights to:

object to the processing of your information, e.g. because you would prefer us not to keep your details as part of recruitment opportunities;

be removed from our marketing lists or change your marketing preferences by contacting [email protected];

request a copy of the information we hold about you;

withdraw consent to our processing of your information (to the extent that such processing is based on consent);

restrict our processing of your information;

ask that we delete or correct the information that we hold about you; and

ask for personal data you have made available to us to be transferred to you or a third party in machine-readable formats.

These rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.

To exercise any of these rights, or if you have any other questions about our use of your information, please contact us at [email protected].

Transferring information internationally
Like many global organisations, we have offices in a number of countries (listed here), use global systems and interact with other parties globally.  For example, Hg engages third-party IT service and software providers which host, store and process data in and outside of the European Economic Area (the “EEA”) and the United Kingdom. This means that your information may be transferred to a country outside the EEA – such as the US, the UK or other non-EEA countries – or to a country outside the UK. These countries may not offer the same level of data protection as in your home country, and may not be deemed as providing an adequate level of data protection under applicable data protection laws (“Non-Adequate Countries”). Where your information is transferred from within the EEA or from within the UK to a Non-Adequate Country, care is taken to ensure that the transfer is subject to appropriate safeguards in accordance with applicable data protection laws. To obtain a copy of these safeguards, please contact [email protected].

Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect.

If you have any questions about this privacy notice, or our privacy related practices, you can contact: [email protected]

If you are unhappy with the way we have handled your information you have a right to complain to your local data protection regulator.

In the UK, your local regulator is the Information Commissioner, whose website is available at  https://ico.org.uk

In Germany, your local regulator is the Bavarian Data Protection Authority, whose website is available is https://www.lda.bayern.de