Arisaig Partners

Privacy Policy

Insights

“Arisaig Partners”, “we”, “us” and “our” means Arisaig Partners (Asia) Pte Ltd, Arisaig Partners Research Services (UK) Ltd, Arisaig Partners (India) Private Ltd, Arisaig Partners (Mauritius) Ltd and any other company in the Arisaig group and for the purpose of data protection law, we will be what’s known as the ‘Controller’ of the personal data you provide to us.

Arisaig Partners (Asia) Pte Ltd is a company incorporated in Singapore and whose registered office is at 6 Lorong Telok, #02-01 Singapore 049019;

Arisaig Partners Research Services (UK) Ltd is a company incorporated in England whose registered office is at Tricor Suite, 4th Floor, 50 Mark Lane, England, EC3R 7QR;

Arisaig Partners (India) Private Ltd is a company incorporated in India and whose registered office is at ONE BKC’ 510, 5th Floor, C Wing, Plot No. C-66, Bandra Kurla Complex, Bandra (East), Mumbai-400051 India; and

Arisaig Partners (Mauritius) Ltd, a company incorporated in Mauritius and whose registered office is at IFS Court, Bank Street Twenty Eight, Cybercity Ebene, 72201 Mauritius.

Arisaig Partners is responsible for ensuring that it uses your personal information in compliance with applicable data protection law. We comply with all applicable data protection law, including the European Union’s General Data Protection Regulation 2016/679 (“EU GDPR”) together with the version of the EU GDPR which is incorporated into the domestic law of the United Kingdom (“UK GDPR”) (the EU GDPR and the UK GDPR are collectively referred to as the “GDPR”), and Singapore’s Personal Data Protection Act 2012 (“PDPA”).

This Privacy Notice explains how we use the personal information that we collect or generate in relation to your use of our website (at https://arisaig.com/) as well as our services. If our processing of your personal data or information is subject to Indian law (for example, you are accessing, using or browsing our website in India), you agree to be bound by this Privacy Notice and give your consent for the purpose of Indian law to the collection, storage, dealing, handling, disclosure or transfer of your personal data or information in accordance with the terms of this Privacy Notice.

Many of the services offered by us require us to obtain personal information about you in order to perform the services we have been engaged to provide. Users may be unable to access the Arisaig Partners website or services if such personal information is not provided. The part of the website that you are accessing as well as the services you are requesting will determine the kind of personal data we might collect and includes:

  • Information that you provide to us. This includes information about you that you provide to us and such information may include (by way of a non-exhaustive list):
    • basic personal data (such as first name; family name; position in the company; companyname; company email address; business phone number; business address; city; postcode; country);
    • any information that you choose to share on our website or services which may beconsidered personal data; and
    • any particularly sensitive personal information or data that you share on our website orin order to use our services (such as financial information such as bank account or credit card or debit card or other payment instrument details, passwords, etc.).
  • Information that we collect or generate about you. This includes (by way of non-exhaustive list):
  • any information regarding the services purchased and/or used on our website and our interactions with you;
  • a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you; and
  • activity data relating to your use of our website.
  • Information we obtain from other sources. This includes the personal data provided to us by third-party service providers, agencies or other publicly available sources where applicable.

Your personal data may be stored and processed by us in the following ways and for the following purposes:

  • to provide you with on-going organisational updates, funding information and analysis services in line with the service we offer;
  • for ongoing review and improvement of the information provided on our websites to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
  • to understand your needs and interests;
  • for the management and administration of our business;
  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
  • for the administration and maintenance of databases storing personal data.However, when we use your personal data we make sure that the usage complies with law and the law allows us and requires us to use personal data for a variety of reasons. These include:
  • we need to do so in order to perform our contractual obligations with our customers and third-party providers;
  • we have obtained your consent or are relying on a statutory exemption from the requirement to obtain consent (where applicable) under applicable law;
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • the use of your personal data as described is necessary for our legitimate business interests, such as:
    • allowing us to effectively and efficiently manage and administer the operation of our business;
    • maintaining compliance with internal policies and procedures; and
    • enabling quick and easy access to information on our products and services.We will take steps to ensure that the personal data is accessed only by employees of Arisaig Partners that have a need to do so for the purposes described in this Privacy Notice.

      Arisaig Partners will also always adhere to the firm’s Cybersecurity & Information Security Policy (CISP).

We may disclose your personal data to our affiliates for the purposes described above. We will take steps to ensure that access to personal data is restricted to Arisaig Partners employees who have a legitimate interest in the purposes described in this Privacy Notice. We may also share your personal data outside of the Arisaig Partners group for the following purposes:

  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
  • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.

The personal data that we collect from you may be transferred to, and stored at, a destination outside jurisdiction of collection of such data. It may also be processed by staff operating outside of the jurisdiction who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the jurisdiction of its collection, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in such jurisdiction. This can be done in a number of ways, for instance:

  • for the transfer of personal data outside of the UK and/or EEA:
    • the country that we send the data to might be approved by the European Commission or the UK Government (as appropriate); or
    • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission or the UK Government (as appropriate), obliging them to protect your personal data;
  • for the transfer of personal data out of India, by taking appropriate measures to ensure that the entity receiving such information in the other country collects, processes or retains the information with the same level of data protection standards that are prescribed under this privacy notice and the data protection laws in India; and
  • for the transfer of personal data out of Singapore:
    • the recipient is otherwise bound by legally enforceable obligations such as applicable local law, any contract that imposes a standard of protection that is comparable to that under the PDPA, binding corporate rules or any other legally binding instrument; or
    • the recipient holds a “specified certification” under the Asia Pacific Economic Cooperation Cross Border Privacy Rules System or the Asia Pacific Economic

Cooperation Privacy Recognition for Processors System.

In other circumstances the law may permit us to otherwise transfer your personal data outside the jurisdiction of collection of the data. In all cases, however, we will ensure that any transfer of your personal data is compliant with applicable data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the jurisdiction of collection of the data (including obtaining a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the contact details provided in the link below under the Section “What are your rights?”.

How long we hold your personal data for will vary and will be determined by the following cumulative criteria:

  • the purpose for which we are using it – Arisaig Partners will need to keep your personal data for as long as is necessary for that purpose; and
  • various legal obligations, such as that under UK tax law, which requires us to keep your basic personal data (name, address, contact details) for a minimum of six years after which time it will be deleted.

If you have given your consent for marketing then we would like to use your name and email address to keep you updated on market and Arisaig Partners developments. This information is not shared with third parties and you can unsubscribe by removing your consent at any time via phone or email.

Our site may, from time to time, contains links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

We may collect personal data about you when you browse our site via “cookies”, which are small text files placed on visitors’ hard drives that enhance the website experience.

Cookies are a standard feature of many websites and are readable only by the organization hosting the website. Cookies cannot access, read or modify any other data on a visitor’s device, nor can they capture any data that allows the organization hosting the website to identify the visitor as an individual.

Specifically, our site uses cookies to measure and improve its performance, as well as to distinguish visitors from each other and detect when a user visits the site multiple times within a 24-hour period (in which case, it will not show the disclaimer text upon subsequent visits by the same visitor).

For more information on the cookies used by us, please see our Cookie Policy www.arisaig.com/cookie-policy/

We reserve the right to amend this Privacy Notice from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on Arisaig Partners website or by contacting you directly.

You have a number of legal rights in relation to the personal data that we hold about you. These rights include but are not limited to:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw your consent to our processing of your personal data at any time. Subject to applicable law, we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request;
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us: and
  • to the extent permitted by law, the right to be notified of a data breach.

If you wish to raise a complaint on how we have handled your personal data or to raise a subject access request, please do so by contacting us using the following contact details depending on where you’re located:

  • If you’re located in the UK, please use the following contact details of our UK representative:Address: Arisaig Partners Research Services (UK) Ltd Tricor Suite, 4th Floor
    50 Mark Lane
    England, EC3R 7QR
    Email Address: dataprotection@arisaig.com
  • If you’re located anywhere else, please use the following contact details:Address: Arisaig Partners (Asia) Pte Ltd 6 Lorong Telok #02-01
    Singapore 049019
    Email Address: dataprotection@arisaig.com

     

    If you wish to raise a concern about Arisaig Partners’ handling of your data you should first contact us at Arisaig Partners using the relevant contact details. If you are unhappy with the response you receive from Arisaig Partners and are located in the UK, you can contact the Information Commissioner’s Office at www.ico.org.uk or contact their helpline on 0303 123 1113. If you are located in the EEA, the relevant supervisory authority name and contact details can be found here.

IMPORTANT NOTICE

PLEASE READ THIS IMPORTANT INFORMATION BEFORE PROCEEDING FURTHER.

Terms of Use

These terms and conditions (the “Terms of Use”) set out the terms on which you may make use of this website, and they apply to every page of this website (collectively, the “Site”), whether or not these terms and conditions appear on each individual page. This page contains legal and regulatory notices relevant to the information contained on the Site. By accessing the Site you agree to be bound by the following terms and conditions.

Arisaig Partners (Asia) Pte Ltd (company registration number 199607401H) (“AP Asia”, “us”, “we” or “our”), a member of the Arisaig Group (together the “Arisaig Group”, and each entity within the Arisaig Group, an “Arisaig Group Entity”), reserves the right, at our discretion, to change, modify, add or remove portions of these terms at any time. Therefore, we suggest that you review these pages periodically for changes. By using the Site after we have posted changes to these terms and conditions of use, you are agreeing to be bound by these terms as amended. If you do not agree to these Terms of Use, you should not use this website.

1. About the Site

The Site, www.arisaig.com, is a website operated by AP Asia. AP Asia is registered in Singapore and has its registered office at 6 Lorong Telok #02-01, Singapore 049019. AP Asia is licensed by the Monetary Authority of Singapore (the “MAS”) pursuant to the Securities and Futures Act (Cap. 289) of Singapore.

When using this Site, you are responsible for complying with all applicable local, national and international laws and regulations, including those related to data privacy, international communications and exportation of technical or personal data. It may be illegal to download the information contained on the Site in certain jurisdictions and we disclaim all responsibility if you download any information from the Site in breach of any law or regulation of the jurisdiction in which you reside or, if different, in which you download such information.

2. Investment Information

The information contained on this Site is provided for general information and, is not an offer to sell, or a solicitation of any offer to buy, any security, investment, or financial service or product.

Opinions expressed on this Site are our opinions only and reflect our views only at the time at which such opinions were expressed. Our opinions reflect our views at such time regarding market conditions and other factors, may depend upon assumptions or projections that may not prove to be correct, and are subject to change.

Nothing contained on the Site is intended to constitute investment, legal, tax or accounting advice. You should consult with your own professional advisors for advice on any investment, legal, tax, or accounting issues relating to matters discussed on this Site.

The information contained on this Site is subject to change without notice. For example, the terms of any security, investment, or financial product or service may be changed without notice.

The distribution of the information contained on the Site in certain jurisdictions may be restricted by law and persons who access it are required to inform themselves and to comply with such restrictions. In addition, this Site and its contents have not been prepared for and are not intended for access by the public in the United States. It is your responsibility to be aware of, to obtain all relevant regulatory approvals, licences, verifications and/or registrations under, and to observe all applicable laws and regulations of any relevant jurisdiction in connection with your entrance to this Site.

Decisions based on information contained on this Site are your sole responsibility. In exchange for using this Site, the visitor agrees to indemnify and hold the Arisaig Group and its officers, directors, employees, affiliates, agents, licensors and suppliers harmless against any and all claims, losses, liability, costs and expenses (including but not limited to lawyers’ fees) arising from your use of this Site, from the visitor’s violation of these Terms of Use or from any decisions that the visitor makes based on such information.

3. Risk Factors

Our investment and financial products and services involve substantial risks. You should carefully consider these risks before investing in or purchasing any financial product or service. In particular, you should carefully review and consider all risk disclosures that are provided for any investment or financial products and services. You should evaluate these risks with your professional advisers.

Our services and products, including investment funds managed or sponsored by an Arisaig Group Entity (the “Arisaig Funds“), are available only to those persons who are financially sophisticated, are capable of evaluating the risks and merits of investing in any such products, can bear the economic risk of an investment in such products for an indefinite period, and can afford the loss of their entire investment. The funds referred to in this Site are not authorised or recognisedby the MAS for sale to the public in Singapore.

By making available information on the Site, Arisaig does not represent that any investment vehicle is available or suitable for any particular user. All persons and entities accessing the Site do so on their own initiative and are responsible for compliance with applicable local laws and regulations.

4. Compliance with Certain Restrictions Relating to the Arisaig Funds

The Arisaig Group Entities and the Arisaig Funds may be subject to restrictions under the law of jurisdictions in which any Arisaig Group Entity seeks to provide offering materials, subscription documents and other documents relating to an Arisaig Fund, to make offers to sell shares of an Arisaig Fund, or to solicit offers to buy shares of an Arisaig Fund. As a result, the information on this Site is not intended to be available to any person in any jurisdiction where access to or use of such information would be contrary to law or regulation or which would subject any Arisaig Group Entity or any Arisaig Fund to any registration requirement within such jurisdiction (such persons, “Prohibited Persons“).

The information on this Site is intended to be available only to persons other than Prohibited Persons. Prohibited Persons should not access, act upon or rely on any such information.

EEA: A number of the Arisaig Funds are non-EU AIFs, as defined in Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers (“AIFMD”). The relevant Arisaig Group Entity which is the Alternative Investment Fund Manager (“AIFM”) of such Arisaig Funds is established outside the EU and, as such, is a non-EU AIFM for the purposes of AIFMD.

The content of this Site may only be made available in each member state of the European Economic Area (“EEA Member State”) to the extent that the relevant Arisaig Fund is permitted to be marketed to a professional investor as defined by AIFMD (“Professional Investor”) in the relevant EEA Member State in accordance with AIFMD or may otherwise be lawfully distributed to a Professional Investor in the relevant EEA Member State at the initiative of the investor. Persons who are not Professional Investors should not rely or act on the contents of this site.

United States: The content of this Site is not directed at or intended for persons, individuals or entities that are US persons as defined by Regulation S of the United States Securities Act of 1933 (the “Securities Act“), as amended (“US Persons“) and no securities or services are being offered in the United States or to US Persons.

Neither AP Asia nor Arisaig Partners (Mauritius) Ltd holds itself out as an investment adviser in the United States and does not offer its services to the general public in the United States. The content of this Site is only intended for the account of a US Person who is a qualified purchaser as defined in the United States Investment Company Act of 1940, as amended (a “Qualified Purchaser“) and an accredited investor as defined under the Securities Act (an “Accredited Investor“).

Switzerland: The Arisaig Funds have not been registered with the Swiss Financial Market Supervisory Authority and the shares in such Arisaig Funds cannot be distributed in Switzerland to non-qualified investors. Any distribution of the shares in Switzerland may only be made to qualified investors as defined in the Swiss Federal Act on Collective Investment Schemes (“CISA“) and its implementing ordinance (“Qualified Investors”). The content of this Site may only be made available in Switzerland to Qualified Investors.

5. Your use of the Site

By using this website, you have indicated that you accept these Terms of Use, and that you agree to abide by them, and that you are not a Prohibited Person. If you do not agree to these terms and conditions, please refrain from using this website.

Except as otherwise stated in these Terms of Use or as expressly authorized by Arisaig Group in writing, you must NOT use this website (or permit or procure others to use it) as follows:

  1. for any unlawful, improper or illegal purpose or activity;
  2. to communicate or receive information that is obscene, indecent, pornographic, sadistic, cruel, or racist in content, of a sexually explicit or graphic nature, which promotes or incites discrimination, hatred or racism or which might be legally actionable for any reason;
  3. in a manner intended to threaten, harass, or intimidate;
  4. to violate any Arisaig Group entity’s or any third party’s copyright, trademark, proprietary or other intellectual property rights;
  5. to damage Arisaig Group entity’s name or reputation or that of an Arisaig Group entity’s affiliated company or any third parties;
  6. to penetrate Arisaig Group entity’s security measures or other entities’ systems (“hacking”);
  7. to introduce viruses, worms, harmful code and/or Trojan horses onto the internet or into this website or any other entity’s systems and it is your responsibility to ensure that whatever you download or select for your use from this website is free from such items;
  8. to use this Site in any manner that could create impression of affiliation, sponsorship, or endorsement of Arisaig Group;
  9. to post or transmit information that is defamatory, fraudulent or deceptive; and/or
  10. to transmit confidential or proprietary information, except solely at your own risk.

6. Our Liability for Your Use of the Site

Access to the Site is permitted on a temporary basis and we reserve the right to withdraw, restrict or amend the terms of access to the Site without notice. We do not accept any liability if, for any reason, the Site is unavailable at any time or for any period.

Although we seek to assure that the information on this Site is accurate and complete at the time of publication, this Site may contain errors or inaccuracies and no representation or warranty (including implied warranties of merchantability and fitness for a particular purpose), expressed or implied, is made (or accepted) as to its accuracy, completeness, reliability or fitness for any purpose by Arisaig Group or any affiliates or third party providers. The information on this Site is provided “as is”. Under no circumstances, including negligence, will Arisaig Group or any of its affiliates or third party providers be liable for any direct, indirect, incidental, special or consequential loss or damages of any kind arising out of or in connection with access to, reliance on or use of the information on this Site. This paragraph does not limit rights available to you under the laws of your jurisdiction and other rights that may not be waived by contract.

All content on this Site is presented only as of the date published or indicated, and may be superseded by subsequent market events or for other reasons. In addition, you are responsible for setting the cache settings on your browser to ensure you are receiving the most recent data.

This Site may include forward looking statements, including projections of future economic and financial conditions. We do not make any representation, warranty, guaranty or other assurance that any of these forward looking statements will prove to be accurate.

This Site may contain or be linked to other third-party websites as a convenience for visitors. Arisaig Group has no control over such other websites, the contents therein or the products/services offered. Arisaig Group makes no representations or guarantees as to the accuracy, subject matter, timeliness or quality of information on any linked sites and assumes no liability for the content or presentation of such linked sites. Arisaig Group has not and will not review or update information on any linked sites and cautions that any use made of such information is at your own risk.

The internet is not a completely reliable transmission medium and neither we nor any of our affiliates accept any liability for any data transmission errors such as data loss or damage or alteration of any kind or for the security or confidentiality of information transmitted across the internet to or from us or any of our affiliates. Any such transmission of information is entirely at your own risk.

Nothing in these terms of and conditions shall exclude or restrict any duty or liability that we may have to any client under a given regulatory system.

7. Intellectual Property Rights

Unless otherwise expressly noted, all information on this Site are the sole property of AP Asia, which holds and reserves all copyrights, trademarks, service marks, trade names, trade dress and other rights in the same. No material on this Site may be copied, reproduced, republished, uploaded, posted, linked into, transmitted (by electronic means or otherwise), or distributed or used in any way without AP Asia’s written permission. Nothing on the Site should be construed as granting any licence or right in relation to any of our copyrights, trademarks, service marks, trade names, trade dress and other rights.

You must not transmit any virus, “worm”, “Trojan horse”, or other item of a destructive nature to the Site and it is your responsibility to ensure that whatever you download or select for your use from the Site is free from such items.

8. Use of Cookies

The Site uses cookies to record your acceptance of disclaimers displayed on the Site. These cookies are necessary for the functioning of the Site and you cannot opt out of receiving these cookies.

The Site also uses cookies for the purposes of measuring and improving performance of the Site. These cookies allow us to distinguish you from other users and to detect when you visit the Site on two occasions in a 24 hour period. You can opt out of receiving these cookies at any time by adjusting your browser settings.

9. Law and Variation

The Site is established in Singapore by AP Asia in accordance with and shall be governed by, and your browsing in and use of the Site shall be deemed acceptance of, the laws of Singapore. A condition of using the Site is that in the event of any dispute or proceeding you irrevocably submit to the exclusive jurisdiction of the Singapore Courts and waive any objection to proceedings in such courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum.

If any specific term or condition of these Terms of Use is determined by a court of competent jurisdiction to be invalid, void or unenforceable, that determination shall not affect the validity of the remaining provisions of these Terms of Use. Headings used in these Terms of Use are for convenience, are not substantive and shall not be used to interpret or construe any of the provisions contained in these Terms of Use. When used in these Terms of Use the words ‘includes’, and ‘including’ shall be deemed to be followed by the phrase ‘without limitation’.

10. Acceptance of Terms

By accessing the Site beyond this point you represent, warrant and confirm that:

  • You are not a Prohibited Person;
  • You are an Accredited Investor within the meaning of the Securities and Futures Act (Cap 289) of Singapore;
  • If you are in the EEA, you are a Professional Investor;
  • If you are in Switzerland, you are a Qualified Investor;
  • If you are in the United States of America, you are a Qualified Purchaser and an Accredited Investor; and
  • You are not otherwise subject to any restriction prohibiting access to this Site imposed by the laws and regulations of your jurisdiction.

If you are unsure about the meaning of any information provided, please consult your financial or other professional adviser.

If you have any enquiries in relation to our site or the information on it, please contact investorrelations@arisaig.com.