Changes to this Policy and Your Duty to Inform us of Changes

We keep our Policy under regular review. It is important that Your Personal Information is accurate and current. Please keep us informed if Your Personal Information changes during your relationship with us. To do so, please contact us at datamanager@m3ig.com.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Information We Collect About You

We collect Your Personal Information from the following sources, as applicable:

1. Client agreements and other information provided by the Client in writing, in person, by telephone, electronically or by any other means (this information includes (i) name, address, income, financial and investment qualifications, and tax-related information, birth date, nationality, passport or other identification number, and employment information); and
2. Other interactions with us (for example, discussions with our staff).

The provision of Your Personal Information is voluntary: you may choose not to provide us with the requested data, but failure to do so may inhibit our ability to do business with you. For example, where we need to collect Your Personal Information by law or under 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. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How We Will Use Your Personal Information

Your Personal Information may be processed by us (or any of its affiliates, agents, employees, delegates or sub-contractors) for the following purposes, as applicable:

1. to facilitate the management and administration of your relationship with us on an ongoing basis (the “Services”) which are necessary to fulfill all related contractual and regulatory obligations;
2. in order to carry out anti-money laundering checks and related actions which we consider appropriate or necessary to fulfill any of our legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with our anti-money laundering policies and procedures;
3. to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
4. to disclose information to other third parties such as service providers (including, for example, attorneys, accountants, auditors, or other professionals), regulatory authorities and technology providers in order to comply with any legal obligation imposed on us or in order to pursue our legitimate interests;
5. to monitor and record electronic communications and, if applicable, calls, for any of the purposes specified herein; and/or
6. to otherwise pursue our legitimate interests relating to your investment and/or where the processing of Your Personal Information would be in the public interest, including where we or another third party must fulfil their regulatory obligations.
7. 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 of our services may be relevant for you.

Change of Purpose

We will only use Your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at datamanager@m3ig.com. If we need to use Your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process Your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

The Manner in Which We Handle and Disclose Your Personal Information

We may share Your Personal Information with third parties, such as service providers. We require all third parties to respect the security of Your Personal Information and to treat it in accordance with the law. We do not allow your third-party service providers to use Your Personal Information for their own purposes and only permit them to process Your Personal Information for specific purposes and in accordance with our instructions.

You should be aware that some of the third parties with whom we share Your Personal Information, may be located outside your country or the country from which Your Personal Information is provided and may be located outside the European Economic Area (“EEA”).

For users within the EEA, Your Personal Information is controlled by M3 Capital Partners (UK) LLP. If we need to share Your Personal Information with a recipient outside the EEA, we will ensure that a similar degree of protection is afforded to it by ensuring that one of the following safeguards is in place:

1. that the transfer of Your Personal Data is to a country that has been deemed to provide an adequate level of protection for personal data by the European Commission (the “EC”);
2. where we use certain service providers, that we have entered into the standard contractual clauses adopted by the EC which give personal data the same protection it has in the EEA; or
3. where we use service providers based in the United States, that they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the United States.

To find out more about the appropriate safeguards that we have in place, please contact us at datamanager@m3ig.com.

Candidate Privacy

Whether you are applying to work with us as an employee, worker or contractor, as part of our candidate application and recruitment activities we collect, process and store Your Personal Information. We will process this as part of the recruitment process which may include assessing your skills, qualifications and suitability, pre-employment background checks, communicating with you about the recruitment process and complying with our legal and regulatory requirements.

We collect Your Personal Information from you, the candidate, recruitment agencies and our background check provider. We may collect special categories of Your Personal Information. We use information about any disability or health condition you may have to consider whether we need to provide appropriate adjustments during the recruitment process.

We are able to legally collect and use Your Personal Information because collecting and using Your Personal Information is necessary for us to:

1. comply with a legal obligation to which we are subject, including our legal obligations under employment laws;
2. perform our contractual obligations as a prospective employer and/or engager of personnel;
3. carry out our legitimate business interests in conducting our business with you as a prospective employee, contractor or other personnel of the business. This legitimate interest includes, but is not limited to, recruitment and administration.

We will only share Your Personal Information with third parties for the purposes of processing your application. We do not allow our third party service providers to use Your Personal Information for their own purposes. We only permit them to process Your Personal Information for specified purposes and in accordance with our instructions.

Data Security

We employ security measures to protect Your Personal Information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage.

In addition, we limit access to Your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your Personal Information and they are subject to a duty of confidentiality.

Data Retention

We will retain Your Personal Information for as long as reasonably necessary to fulfil the purposes we collected it for or for as long as the law requires. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe that there is a prospect of litigation in respect of the provision of the Services or the processing of Your Personal Information.

To determine the appropriate retention period for Your Personal Information, we consider the amount, nature, and sensitivity of Your Personal Information, the potential risk of harm from unauthorized use or disclosure of Your Personal Information, the purposes for which we process Your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Legal Rights

Under certain circumstances, you have rights in relation to Your Personal Information. You have the right to:

1. request access to Your Personal Information and ask us to provide a copy of Your Personal Information we hold about you;
2. request correction of Your Personal Information if it is inaccurate or incomplete at any time;
3. request erasure of Your Personal Information, which means you can request deletion or removal of any of Your Personal Information we hold about you at any time, subject to our rights to retain Your Personal Information;
4. object to the processing of Your Personal Information;
5. request restriction of processing Your Personal Information;
6. request transfer of Your Personal Information; and
7. withdraw your consent to the use of Your Personal Information, as described below.

To exercise any of your rights as listed above, please contact us at datamanager@m3ig.com.

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

We may need to request specific information from you to help us confirm your identity and ensure that you have a right to access Your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Your Personal Information 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.

You will not normally have to pay a fee to access Your Personal Information. However, in the event that a request is unfounded, excessive or especially repetitive, we may charge a reasonable fee for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information. That reasonable fee will be based upon the administrative costs of providing the information.

Withdrawal of Your Consent

You can tell us to stop collecting, using and retaining Your Personal Information at any time by emailing us at datamanager@m3ig.com. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. You should note that notwithstanding the withdrawal of your consent, we may be legally required to retain some or all of Your Personal Information.

Changes to this Policy

Any changes to this Policy in the future will be posted to the website and, where appropriate, through email notification. Any changes we may make to this Policy will be effective upon posting.

By using this website you consent to us using Your Personal Information in the manner set out in this Policy.

This Policy was last updated on March 23, 2023.

If you have any questions, comments or requests regarding our Policy, please contact our Data Manager using the details set out below:

By post to:

Data Manager
M3 Investment Group LLC
150 South Wacker Drive, Suite 3100
Chicago, IL 60606

By email to:

datamanager@m3ig.com

If your habitual residence or place of work is within the EEA, and you are unhappy with our processing of Your Personal Information, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence or place of work or in the place of the alleged infringement. We would, however, appreciate the chance to deal with any concerns before you approach the supervisory authority, so please contact the Data Manager by email in the first instance.