Mithras Capital Partners LLP
Terms and Conditions · Privacy Policy
Mithras Capital Partners LLP

Privacy Policy

Mithras Investment Trust plc is committed to protecting your personal data and we have strict policies and procedures governing your personal data. This Privacy policy explains how Mithras Investment Trust plc collects, stores and uses your personal data.

Personal data means any information relating to an identified or identifiable natural person (data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

Any reference in this Privacy policy to "Mithras" means Mithras Investment Trust PLC, or any of its subsidiaries. For the purposes of applicable legislation, including the EU General Data Protection Regulation, as amended or supplemented (the "Data Protection Laws"), the relevant Mithras entity that you have dealings with is the controller of your personal data.

Personal data in relation to shareholders in Mithras Investment Trust plc
The personal data of all our shareholders who hold shares directly, or details of the nominee accounts in which some retail and institutional shareholders hold their shares, are held and maintained by Mithras Investment Trust plc's registrar, Equiniti Limited. Shareholder information is collected and maintained on our behalf for the purposes of:
  • complying with our regulatory and legal obligations;
  • communicating with shareholders (including the mailing, in physical or electronic format, of Annual Reports, AGM or EGM notices or proxy cards, or communications in relation to other corporate actions such as tender offers); and
  • facilitating the payment of dividends or proceeds from tender offers.
The personal data we hold about shareholders may be shared with:
  • companies who process personal data on Mithras Investment Trust plc's behalf, such as our shareholder registrar Equiniti Limited;
  • professional advisors, such as accountants, lawyers, proxy advisers or other consultants; and
  • other companies in the Mithras group.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal data about you is that such processing is necessary for our legitimate interests in running and operating our business and ensuring effective communications with shareholders.

Personal data of third party service providers, suppliers and professional advisors
If you are a third party service provider or supplier to Mithras, or one of its professional advisors, we will store limited amounts of personal data relating to you, including your name, job title, qualifications, employer organisation and contact details. We will store this personal data for the purposes of:
  • maintaining a record of contacts for our third party service providers, suppliers and professional advisers;
  • administering and maintaining records of services or advice we have received, managing and running our business and/or commissioning further services.
The personal data we hold about third party service providers, suppliers and professional advisors may be shared with:
  • professional advisors, such as accountants, lawyers or other consultants; and
  • other companies in the Mithras group.
In accordance with the Data Protection Laws, our legal basis for storing personal data that you provide to us is that such storage is necessary for our legitimate interests in running our business.

Personal information in relation to fund investments made by Mithras Capital Fund LP or investors in Mithras Capital Fund LP
If you are involved in the operation or management of a fund investment made by Mithras Capital Fund LP or are an investor in Mithras Capital Fund LP, we may store personal data relating to you. This will include your name and contact details but could also include your CV, details of your previous employment history and professional activities, information relating to your financial and tax status including tax residency and tax reference numbers, copies of identity documents, such as a passport, references provided by third parties, and results of other due diligence carried out. We collect and store this data for the purposes of:
  • assessing potential fund commitments;
  • maintaining records of fund commitments;
  • administering any fund commitment or investor admitted to Mithras Capital Fund LP;
  • assessing your suitability for involvement in a transaction, including by verifying your identity;
  • complying with our regulatory and legal obligations, including assessing and managing risk;
  • safeguarding our legal rights and interests;
  • seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
  • providing reporting and / or periodic business updates, as described below.
The personal information we hold about actual or potential management teams may be shared with:
  • companies who process personal data on Mithras' behalf, such as third party service providers;
  • professional advisors, such as accountants, lawyers or other consultants;
  • other companies in the Mithras group.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal data about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential fund investments, and administering Mithras Capital Fund LP. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal data for the purpose of performing that contract and to comply with our regulatory and legal obligations.

Mandatory requirement to provide personal data
We will only use or disclose your personal data for the purpose it was collected for and as otherwise identified in this Privacy policy. There may be circumstances where we are required to provide your personal data to third parties. We will explain to you when the provision of particular information is mandatory, including the possible consequences of not providing particular information. Personal data may be provided to third parties, including anti-fraud organisations or legal, regulatory or law enforcement authorities in cases of suspected criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments, regulatory authorities or other self-regulatory organisations, or to comply with a court order. Unless prohibited by law, we can give you details of any such third party disclosures upon request.

Transfers of personal data
Your personal data may be accessed, transferred to, and/or stored in, a country outside the European Union in which data protection laws may be of a lower standard than within the European Union. Regardless of location, we will impose the same data protection safeguards that we use inside the European Union. If you would like more information about how your personal information may be transferred, please contact us using the contact details below.

Retention of personal data
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and /or records of service provided until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data or securely destroy the data.

Your rights
Individuals whose personal data we hold may be entitled to access their personal data, or to request that it is erased, that its processing is restricted, or that any inaccurate personal data is rectified. You may also have the right to object to the processing of your personal data, or in some circumstances to obtain a copy of the personal data in machine readable format. Any such request should be submitted in writing to the Managing Partner, Mithras Capital Partners LLP (bernie.boylan@mithrascapital.com). Individuals also have the right to complain about the use of their personal data to the Supervisory Authority, which in the UK is the Information Commissioner's Office (www.ico.org.uk).

Accuracy of personal data
Mithras will take all reasonable steps to keep your personal data accurate and, where necessary, up to date. If you believe that any of the information that Mithras holds about you is incorrect please notify Mithras (bernie.boylan@mithrascapital.com).

Security and safeguarding of personal data
We use a range of safeguards to protect your personal data. We have agreements and controls in place with third party service providers requiring them to safeguard any personal data we provide to them and use the personal data only for the purpose of providing the service we have requested them to perform.

Mithras will take all reasonable steps to protect the confidentiality and security of your personal data, but cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing data online over the Internet and will not hold Mithras responsible for any breach of security unless this is due to Mithras's negligence or wilful default.

The Mithras website may contain hypertext links to external websites. Mithras is not responsible for and accepts no liability in relation to these websites or their contents. You should read any applicable privacy policy on any such website.

Periodic business updates
We may use personal data that we hold to send you periodic updates or circulars concerning Mithras's business activities, in particular, by email and post. You can opt out of receiving updates at any time by contacting us. (bernie.boylan@mithrascapital.com).

Mithras Data Privacy Contact
For all enquires please email bernie.boylan@mithrascapital.com.

Changes to Mithras's Privacy Policy
Any changes to this Privacy Policy will be posted here on the website, so please check Mithras's Privacy Policy on a regular basis when you visit our website.