AlpInvest Partners B.V.
External Privacy Policy
Version 1.0 (effective as per 1 May 2018)


1. Introduction

This is the Privacy Policy of AlpInvest Partners B.V. (AlpInvest, we, us).
We have our registered office at the Jachthavenweg 118 in (1081 KJ) Amsterdam, the Netherlands. We are registered with the trade register of the chamber of commerce under company number 27186537.

This Privacy Policy also applies to AlpInvest US Holdings LLC and AlpInvest Partners Ltd. (for administrative convenience purposes only and not as a result of regulatory requirements), as these entities operate on an integrated basis with AlpInvest Partners B.V. for which reason the information included herein is relevant for these entities as well.

We are one of the largest private equity investors in the world. We have affiliates in the United States and in Hong Kong. Further, AlpInvest is part of The Carlyle Group (Carlyle), one of the world’s largest alternative asset managers. Our ultimate parent is a publicly traded company in the United States listed on the Nasdaq stock exchange.

In the context of our activities, we collect, hold, use and further process personal data of various individuals who are involved with our business activities. Pursuant to applicable data protection and privacy legislation, we qualify as the controller with respect to such personal data.

This policy is intended to complement and supplement the Carlyle Privacy Notice and Safeguarding Policies and Procedures to ensure compliance with Dutch privacy regulations, including without limitation the General Data Protection Regulation. In case of discrepancies between the Carlyle policy and this policy, the more restrictive requirement shall control.

2. We highly value data protection and privacy

We recognize the importance of data protection and privacy and, hence, strive to protect the personal data we process in accordance with applicable data protection legislation and more specifically with the Dutch Data Protection Act (Wet bescherming persoonsgegevens) and as per 25 May 2018, the General Data Protection Regulation and relevant national (implementing) legislation.

In this Privacy Policy we set forth how we collect personal data, for what purposes we may use personal data and to whom personal data may be disclosed by us. Further, this Privacy Policy includes important information regarding the rights of the individuals whose personal data we process (each a data subject). In view hereof, we encourage data subjects to carefully read this Privacy Policy

From time to time, we may need to update this Privacy Policy. The most recent version of this Privacy Policy is available on our website.

NOTE: Where you provide personal data to us, which personal data relate to another individual than yourself (for example, when you send us a copy of a colleague’s passport), please ensure that this individual is aware thereof and is referred to this Privacy Policy on our website prior to providing us with his/her personal data. It is our obligation to ensure that all individuals whose personal data we process are aware of and understand the information in this Privacy Policy. However, in certain cases, we do not have any direct contact with such individuals for which reason we rely on you to provide the information on our behalf (for example, generally we do not have direct contact with ultimate beneficial owners of investors that committed to one or more funds we manage, but we do require to process their personal data).

3. Whose personal data do we collect and how?

In the context of our activities, we may collect and process personal data of the following data subjects:
  • contact persons of our current, prospective and former clients and (co-)investors
  • directors, officers, proxyholders and other authorized representatives of current, former and prospective institutional investors and their ultimate beneficial owners
  • current and prospective private clients and investors, also referred to as High Net Worth Individuals
  • directors, officers, employees and other representatives of privacy equity fund managers and portfolio companies in which AlpInvest has made an investment or is considering making an investment
  • directors, officers, authorized representatives of relationship general partners and co-investors
  • representatives of third party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by AlpInvest
We may collect personal data relating to these data subjects in various ways:
  • directly from the data subject (e.g. pursuant to a subscription agreement or by receipt of an email or business card);
  • indirectly from other sources (e.g. from public records or from a counterparty in possession of the data).

4. What personal data do we collect and for what purposes do we use that personal data?

Below, please find an overview of the types of personal data that we may collect and process per category of data subject, as well as an overview of the specific purposes for which we may use these personal data and the legal ground on which we base such processing activities:

Contact persons of our current, prospective and former clients and (co-)investors, of private equity fund managers and portfolio companies and relationship general partners
Personal data: Legal ground and purposes of processing:
full name
telephone number(s)
email address
function/position/title
employer
company details
publically available information (for example in trade register)
for the legitimate interests of AlpInvest or a third party (such as our client), to negotiate and execute an agreement with our clients and (co-)investors, to provide the requested services to our clients and (co-)investors, to create a client account and to manage such account, in order to contact our client and (co-) investors for updates on matters regarding the investments of our clients and (co-)investors (for example to send our clients and (co-)investors reports on returns on investment), to carry out other activities related to client and financial management and administration.

for the legitimate interests of AlpInvest or a third party (such as the prospect), in order to investigate, assess and advise on the feasibility of the prospect’s objectives.

for the legitimate interests of AlpInvest or a third party, for marketing purposes, to inform our clients and (co-)investors about AlpInvest and our services, to invite persons to attend events and meetings (and keep record of attendees) and for general communication purposes.
Directors, officers, proxyholders, authorized representatives of current, prospective and former institutional investors
Personal data: Legal ground and purposes of processing:
full name*
address*
date of birth*
function/position/title
telephone number*
facsimile number
email address*
copy of passport, and the nature, the number and the date and place of issuance of the passport
tax identification number*
information on criminal history/unlawful conduct*
information on investment experience and aims*
source of wealth*
total of assets
power of attorney (where applicable)*
copy of driver’s license*
utility bill/or other document by means of which we may verify your identity *
to comply with legal obligations, for example to comply with our obligations regarding know-your-client and anti-money laundering.

for the legitimate interests of AlpInvest or a third party, to verify the identity and (scope of proxy) of an individual that is representing our institutional client, to evaluate new clients and (co-)investors and to investigate, assess and advise on the feasibility of our clients’ and (co-)investors’ objectives.

for the legitimate interests of AlpInvest or a third party (such as our client), to negotiate and execute an agreement with our clients and (co-)investors, to provide the requested services to our clients and (co-)investors, to create a client and (co-)investor account and to manage such account, in order to contact our client and (co-)investors for updates on matters regarding the investments of our clients and (co-)investors (for example to send our clients and (co-)investors reports on returns on investment), to carry out other activities related to client and financial management and administration.

for the legitimate interests of AlpInvest or a third party (such as our client), to perform analyses and statistics (on an aggregate basis) relating to the types of clients and (co-)investors we service.

for the legitimate interests of AlpInvest or a third party, for marketing purposes, to inform our investors and (co-)investors about AlpInvest and our services, to invite persons to attend events and meetings (and keep record of attendees) and for general communication purposes.
Directors, officers, employees and authorized representatives of relationship general partners, co-investors, private equity funds and portfolio companies in which AlpInvest has made an investment or is considering making an investment
Personal data: Legal ground and purposes of processing:
full name
address
telephone number
facsimile number
email address
function/position/title
copy of passport
tax identification number
information on criminal history/unlawful conduct
source of wealth
power of attorney (where applicable)
copy of driver’s license
publically available information (for example in trade register)
utility bill/or other document by means of which we may verify your identity*
photographs
for the legitimate interests of AlpInvest or a third party (such as our client), to assess the quality of the management of a target in which AlpInvest considers to invest and to investigate, assess and advise on the feasibility of our clients’ and investor’s objectives, as well as to make investment selections and decisions.

for the legitimate interests of AlpInvest or a third party (such as our client), to verify the identity and (scope of proxy) of an individual that is representing the target.

with respect to the photographs, for the legitimate interests of AlpInvest, to use in connection with AlpInvests’ annual GP event, for networking purposes.
Ultimate beneficial owners
Personal data: Legal ground and purposes of processing:
full name*
address*
date of birth*
telephone number*
facsimile number*
email address*
copy of passport, and the nature, the number and the date and place of issuance of the passport*
tax identification number*
information on criminal history/unlawful conduct*
information on investment experience and aims*
source of wealth*
total assets
information on income
information on investments
copy of driver’s license*
utility bill/or other document by means of which we may verify your identity*
to comply with legal obligations, for example to comply with our obligations regarding know-your-client and anti-money laundering.

for the legitimate interests of AlpInvest or a third party, to negotiate and execute agreements with our clients and (co-) investors, for example to provide the requested services to our clients and (co-)investors, to create a client account and management of such account, in order to contact our clients and (co-)investors for updates on matters regarding to the investments of our clients and (co-)investors (for example to send our clients and (co-)investors reports regarding returns on investments) and other activities relating to client management, financial management and administration.

for the legitimate interests of AlpInvest or a third party
, to evaluate new clients and (co-)investors and to investigate, assess and advise on the feasibility of our clients’ objectives. for the legitimate interests of AlpInvest or a third party, for marketing purposes, to inform our clients and (co-)investors about AlpInvest and our services, to invite persons to attend events and meetings (and keep record of attendees) and for general communication purposes.
High Net Worth Individuals
Personal data: Legal ground and purposes of processing:
full name*
address*
date of birth*
place of birth*
citizenship*
occupation*
tax identification number*
bank account details*
total of assets
information on investments
information on income*
information on investment experience and aims
information on criminal history/unlawful conduct
copy of passport*
copy of driver’s license*
source of wealth*
utility bill/or other document by means of which we may verify your identity*
to comply with legal obligations, for example to comply with our obligations regarding know-your-client and anti-money laundering.

to perform an agreement entered into with the data subject
, to negotiate and execute agreements with the High Net Worth Individual, in order to perform the requested services, to create a client account and management of such account, asset management and to contact our client for updates on matters regarding to the investments of our client (for example to send our client reports regarding returns on investments) and other activities relating to client management and administration.

for the legitimate interests of AlpInvest or a third party, for marketing purposes to inform our clients about AlpInvest and our services.
Representatives of third party sellers, placement agents, finders, investment bankers, consultants, lawyers, accountants, advisers and other service providers, whether or not engaged by AlpInvest
Personal data: Legal ground and purposes of processing:
full name
telephone number
email address
function/position/title
employer
company details
for the legitimate interests of AlpInvest or a third party (such as our advisors), to negotiate and execute agreements, carry out the agreement entered into by and between AlpInvest and our contracting party and to contact and communicate with our contracting parties.

for the legitimate interests of AlpInvest or a third party (such as our advisors), to maintain a database in which all service providers engaged by AlpInvest are recorded in order to create a network and to know who to contact in a certain situation

for the legitimate interests of AlpInvest or a third party, for marketing purposes.
*In order to be able to render our investment services to our clients and to enter into an agreement with us, our clients must ensure that, where relevant, all personal data marked with an asterisk (*) are provided to us.

In addition to the specific purposes as listed in the overview above, we may also process all personal data for the following general purposes:
  • for the legitimate interests of AlpInvest or a third party (such as our affiliates), to handle complaints and queries relating to our services, to handle any disputes that may arise.
  • for the legitimate interests of AlpInvest or a third party (such as our affiliates), to monitor and audit compliance of AlpInvest with internal policies and codes of conducts, legal obligations and to meet requirements and orders of (regulatory) authorities, to investigate and take appropriate action in the event of suspected irregularities (such as suspected fraud or offences), to establish, exercise and defend a legal position, which includes the necessity to file and back-up certain information as evidence that may be produced in judicial proceedings.
  • for the legitimate interests of AlpInvest or a third party (such as our affiliates), such as protecting its business, properties and employees or third parties interests, for example by means of audits and investigations (for example to ensure compliance with company policies or in the event of suspected data breaches, fraud or other violation or criminal offence), to monitor and audit compliance of AlpInvest with internal codes of conducts and regulation and in order to enable our affiliates to comply with legal obligations and requests from competent authorities.
  • for the legitimate interests of AlpInvest or a third party, in the context of a (potential) business transaction (such as the sale of (parts of) of its assets or shares, or a merger, for example, by making personal data available to advisors or (potential) buyers.

5. With whom do we share your personal data?
AlpInvest may share certain of the aforementioned personal data with third parties, such as group companies of AlpInvest (including Carlyle), the funds in which investments are made (which funds may (partly) or may not be administered by AlpInvest), investment vehicles to which AlpInvest (envisages to) make any capital commitment, our clients and (co-)investors, (regulatory) authorities (such as tax authorities, financial intelligence units and supervisory authorities), and third parties that provide services to AlpInvest (such as trusted advisors, consultants and other service providers that may require personal data to render their services to AlpInvest). We will only share your personal data with these parties if such is necessary for the purposes as listed above.

In the context of the processing activities as described above, we may also engage third parties to process the personal data on our behalf (for example providers of certain IT applications that we use in the context of our activities). We will enter into the required contractual arrangements with those parties to ensure lawful and fair processing of your personal data on our behalf.

Some of the parties with whom we may share your personal data will be located in countries outside the European Economic Area (such as certain of our affiliates and our parent company in the United States), which countries may offer a lower level of data protection than the Netherlands. In such case, AlpInvest shall ensure that the international transfer of your personal data shall comply with the applicable data protection laws. For instance, AlpInvest may share certain personal data with its parent company Carlyle, located in the United States. In connection herewith, AlpInvest and Carlyle have entered into a data transfer agreement based on the EU Model Clauses (a copy of which can be obtained from us via the contact details below).

6.How do we protect your personal data?
We have implemented the necessary administrative, technical and organizational measures for ensuring a level of security appropriate to the specific risks that we have identified in relation to the processing of personal data. We protect your personal data against destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed.

Further, we seek to ensure that we keep your personal data accurate and up to date. However, you are responsible for and we kindly request that you inform us of any changes to your personal data (such as a change in your contact details).

7.How long do we keep your personal data?
Your personal data will not be kept by AlpInvest for longer than necessary in relation to the purposes for which we collect and use the personal data (we refer to the purposes as set forth above). AlpInvest will retain your personal data in accordance with its Books & Records Policy. If you have any specific question in this respect, please feel free to contact us.

8. What are your rights and who may you contact if you have further questions?

Under certain circumstances, a data subject has the right to ask us to (i) be informed on the personal data we have about him/her, and/or to (ii) access, rectify, erase, restrict the use of his/her personal data. Further, a data subject may have the right to object to the use of his/her personal data by us and/or to ask us to provide the relevant personal data to another party.

To exercise these rights, or in case of questions on how we collect and use personal data, please contact our Chief Legal Officer, by email: Patrick.de.van.der.Schueren@alpinvest.com. In case of complaints about the way in which we process personal data, you may lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

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The materials contained herein are made available solely to provide transparency about AlpInvest and its business. The materials do not constitute an offer to sell or a solicitation of an offer to purchase interests in any managed account or private investment fund or any other investment advisory service or product. Any such offer or solicitation will be made only through a private offering pursuant to a confidential private placement memorandum and/or the related subscription documents. Neither you nor any of your representatives may use the information provided herein for the purposes of evaluating a potential investment in an managed account or a private investment fund. AlpInvest may cease providing access to the materials at any time in its discretion.

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