Privacy & Cookies Policy

General

This Privacy & Cookies Policy sets out how Centricus processes data, whether on individuals (including personal data in respect of individuals, intermediaries or other third parties Centricus interacts with, or any individual who is connected to those parties) or otherwise. Where the data held are on individuals, this document sets out the rights of those individuals in respect of that personal data. Additionally, it sets out the data processing practices using the internet and any other electronic communications networks by Centricus.

In the first instance, please direct any questions in relation to this Privacy & Cookies Policy or requests in respect of personal data to info@centricus.com.

Who we are

‘Centricus’ is the trading name of Centricus Partners LP and certain of its group undertakings (together ‘Centricus Group’).

The data we hold

Centricus processes data in order to provide its services. The type of data we may collect and process includes:

  • Contact details (including names, postal addresses, email addresses and telephone numbers);
  • Information required for Centricus to meet legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including information on source of funds and source of wealth;
  • Information provided in the course of the provision of our services;
  • Financial information;
  • Meetings attended and visits to our offices;
  • Information collected via our website;
  • Any other information you may provide to us.

Use of cookies

Our website uses cookies. A cookie is a small piece of information placed on your computer and sent by a web server to a web browser, which enables the server to collect information from the browser. Find out more about the use of cookies on www.allaboutcookies.org and http://www.cookiecentral.com.

We use cookies to improve the functionality of our website, identify you when you visit this website, keep track of your browsing patterns and build up a demographic profile.

Cookies can be disabled by changing the settings on your browser. If you want to know how to turn off cookies, please look at the help menu on your browser. If you decide to disable cookies it may restrict your use of our website.

By continuing to use and browse this website without changing your settings, you consent to our use of cookies in accordance with this Policy. If you do not consent, you must disable cookies or refrain from using this website.

Our website may contain links to other websites, which are outside our control and are not covered by this Privacy & Cookies Policy. If you access other sites using the links provided, the operators of these sites may collect information from you, which will be used by them in accordance with their privacy policy, which may differ from ours.

Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis.

Purposes of processing

We use data (including personal data of individuals) for the following purposes:

PurposeLawful basis for processing
To provide our servicesAny one or more of the following: The legitimate
interest of Centricus as a service provider to
process personal data for the purpose of providing our services In instances where an individual has been provided with this Privacy & Cookies Policy and provides personal data thereafter, the processing may be carried out on the basis of consent. Consent
may be withdrawn at any time by writing to info@centricus.com The processing is necessary
for ongoing investments or transactions, the
obtaining of external professional advice or the
exercising of legal rights
To manage our client, intermediary and other business relationships  The legitimate interests of Centricus to ensure
its business is conducted efficiently and with a
view to enhancing client service
To ensure the security of Centricus systems, staff and premises (including the use of CCTV equipment)The legitimate interests of Centricus in protecting
its systems, staff and premises from being
misused or the victim of any criminal activity
To share project-related data and communicate with our clientsThe legitimate interests of Centricus and the
recipient for communication, and the provision
of relevant project-related material (access being
subject to a signed non-disclosure agreement and our terms and conditions) In instances where any recipient has been provided with this Privacy
& Cookies Policy and provides personal data
thereafter, the processing may be carried out on the basis of consent. Consent may be withdrawn at any time by writing to info@centricus.com
To meet all legal, regulatory and ethical obligations applicable to Centricus (including in respect of managing potential conflicts of interest)The legitimate interests of Centricus as a provider of legal and governance services to process data to the extent necessary to ensure it meets all legal,
regulatory and ethical obligations incumbent on it. In certain instances, the processing of data may also be necessary for the exercise of functions of public authorities and/or necessary for compliance with a legal obligation to which Centricus is subject.
For the purposes of internal know-how and trainingThe legitimate interests of Centricus to process data for the purposes of internal know-how and staff training. Centricus will use reasonable endeavours to ensure any personal data
contained in the material which is not integral to the understanding of the material is redacted.


In certain instances, personal data processed may include more sensitive personal data which requires special protection (in accordance with Article 9 of the General Data Protection Regulation (EU) 2016/679). Centricus will only collect such data with the data owner’s express consent and in instances where processing is necessary for compliance with a legal obligation or the purpose of legal proceedings.

Sources and recipients of data

The sources of data may include clients, intermediaries, external professional advisers, financing sources, representatives, data subjects directly, third parties connected to the data subject (for example, their employer or another service provider who provides services to the data subject) or open-source material.

The provision of data to one entity in Centricus Group may result in that data being accessible by all other members of the Centricus Group. Reasonable endeavours are made to ensure that data is only accessible by those with a need for access to fulfil the purposes set out above.

Requests for access to be restricted in any particular manner should be made to info@centricus.com and will be considered and, where possible with reference to legal and regulatory obligations, actioned.

Recipients of data may include (but are not limited to) other members of the Centricus Group, third party service providers Centricus collaborates with, or other legal, regulatory or other competent authorities with a legal, regulatory or contractual right to access such data. Centricus will seek to enter into an agreement setting out the respective obligations of each party with regard to data processing and protection against unauthorised or accidental use, access, disclosure, damage, loss or destruction.

Centricus may in the event that any such third party is outside of the European Union and where the data being transferred would include personal data which would be protected under applicable data protection regulation we will ensure we meet the relevant requirements of that data protection regulation prior to carrying out any such transfer. This may include only transferring the data where we are satisfied that:

  • the non-European Union country has data protection laws similar to the laws in the European Union;
  • the recipient has agreed through contract to protect the information in the same data protection standards as the European Union;
  • we have obtained consent from relevant data subjects to the transfer; or
  • if transferred to the United States of America, the transfer will be to organisations that are part of the Privacy Shield.

Rights of data subjects

Data subjects in the European Union (or any jurisdiction with equivalent legislation to the European Union General Data Protection Regulation) have certain rights in respect of their personal data.

If you as a data subject wish to exercise any rights under applicable data protection laws (including the right to withdraw any consent to processing previously given; the right of access to data; or to have data corrected, updated, rectified or erased; or for access to data to be restricted or provided to any third party; or to object to any particular processing), please send a request to Centricus’ Compliance team via info@centricus.com.

Should you as a data subject choose not to provide any personal data or where any of the rights set out above are exercised to limit the processing of personal data, Centricus may be unable to provide relevant services to you, or there may be a restriction on the services which can be provided.

Retention

Centricus only keeps data for as long as necessary to fulfil the purposes for which we collected it. Centricus’ policy is to retain data in relation to a project for 11 years from the completion or termination of a project unless agreed otherwise between the relevant parties. This is subject to certain exceptions, e.g. in instances where the personal data is relevant to a dispute or where the data cannot be deleted for legal, regulatory or technical reasons.

Please make any requests for further information in relation to the continued processing of specific data, and requests for destruction of data, to info@centricus.com.

Data-controlling entities

Centricus Partners LP is the ultimate data controller for Centricus Group. In addition, certain other Centricus entities may act as data controllers. These are registered as data controllers in the relevant jurisdictions. In respect of any relationship with Centricus, the primary data controller will be the entity you are contracting with.

Contact details

Please direct all enquiries in respect of this Privacy & Cookies Policy or any request to exercise any of the rights set out above to Centricus’ Compliance team via info@centricus.com or by post to: Centricus Partners LP, 13 Castle Street, St. Helier, Jersey, JE4 5UT, Channel Islands.

Changes to this Privacy & Cookies Policy

We keep this Privacy & Cookies Policy under review and any updates will appear on our website at www.centricus.com. We last updated this Privacy & Cookies Policy on 21 May 2018.

How to contact us

If you have any questions about this Privacy & Cookies Policy or any data which we hold about you, please contact: info@centricus.com.