Bardin Hill Investment Partners LP (together with its affiliates, Bardin Hill) is committed to keeping your non-public personal information secure and confidential. This notice is intended to help you understand how we fulfill this commitment. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. The meaning of Personal Data is that given in the European General Data Protection Regulation and includes any information relating to an identifiable individual (e.g., name, address, date of birth, or economic information).
Details of how this Privacy Notice applies to individual residents in the European Economic Area “EEA” can be found under the section headed General Data Protection Regulation, below.
This Privacy Notice applies to the ways we interact with individuals connected to our business, including:
We respect the privacy of individuals, with respect to collecting, holding, storing, using, and processing your Personal Data, we:
Please note that Bardin Hill will update this Privacy Notice from time to time and in response to regulatory changes. We may also provide additional privacy notices or similar disclosures in respect of certain categories of individuals (e.g., certain investors or prospective investors in a fund managed or advised by Bardin Hill, or certain former or existing employees associated with Bardin Hill), as well as certain geographies and jurisdictions.
Data We Collect
In connection with our business, we collect various types of Personal Data, depending on the relationship and circumstance, including:
Sharing Personal Data
We may share your Personal Data with certain parties, including:
We and the parties outlined above will process your Personal Data in order to:
Bardin Hill and the parties outlined above will collect and process your Personal Data where necessary or appropriate. Where we share your Personal Data with a third party, we require the recipients to implement adequate measures to protect it.
Your Personal Data may also be shared with law enforcement agencies, regulatory or tax authorities, and other governmental or public agencies or authorities in order to comply with our legal or regulatory obligations or at their request in furtherance of their objectives.
The Fund, the Administrator, and the Investment Manager will not be able to accept your subscription to the Fund without processing your Personal Data for the purposes identified within the “Lawful Basis for Processing Personal Data section” below.
Collecting Personal Data
We collect this Personal Data in various ways, including:
The Lawful Basis for Processing Personal Data
We use your Personal Data for a variety of reasonable and legitimate business purposes, including:
We also use your Personal Data for other purposes, such as:
We will not use your Personal Data for purposes inconsistent with this Privacy Notice without your permission.
Retaining Personal Data
We will keep Personal Data for as long as is necessary for the purposes for which we collect it. The precise period will depend on the purpose for which we hold your information. In addition, as a regulated financial services institution, certain laws and regulations require Personal Data be retained for minimum periods.
Keeping Your Personal Data Current
We endeavor to 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, including changes in your contact details.
European General Data Protection Regulation
Certain information contained within this Privacy Notice applies to individual residents (Data Subjects) in the European Economic Area and is provided in line with the General Data Protection Regulation (GDPR) and secondary or domestic laws implementing the foregoing (together, Data Protection Legislation). The Data Protection Legislation prescribes the way companies, funds, and/or their agents and service providers (including Administrators) may collect, retain, and handle personal information.
Bardin Hill Loan Advisors (UK) LLP (BHLAUK) has been appointed as the European Union (EU) representative and controller of your personal data for Bardin Hill. BHLAUK is authorized and regulated by the UK Financial Conduct Authority and registered with the UK Information Commissioner’s Office. BHLAUK maintains its registered office at 70 Jermyn Street, 3rd Floor, London, UK SW1Y 6NY.
Transferring Your Personal Data Outside of Europe
Bardin Hill transfers your information to entities within countries that provide a different level of data protection from the United Kingdom, including the United States. In such circumstances, we have processes designed to protect your information.
Processing Your Personal Data: Your Rights
European Data Subjects have various rights under the Data Protection Legislation in relation to the Personal Data Bardin Hill collects about you and processes, including:
With regards to the rights afforded to European Data Subjects, if you object to your Personal Data being used to contact you in respect of prospective products and services, please contact a representative of Bardin Hill known to you or email us at privacy@bardinhill.com. As a European Data Subject you may also have the right to file a complaint about the processing of your Personal Data with your local data protection authority in the EU.
With regards to the rights afforded to European Data Subjects, you will not have to pay a fee to access your Personal Data or to exercise any of the other rights. However, we reserve the right to charge a reasonable fee if your request for access is manifestly unfounded or excessive.
Questions
If you have questions or complaints regarding Bardin Hill collecting or processing your Personal Data please contact us at privacy@bardinhill.com.