General Information

What information do we have about you?

How do we process your personal data and why is this justified?

Who has access to your personal data and to whom are they transferred?

How do we protect your personal data?

How long do we store your personal data?

What are your rights and how can you exercise them?

Who can I contact if I have any questions or concerns?

How will you be informed of the changes to our Privacy Notice?

 

General Information

1 This is the Website Privacy Notice for Partners Group Listed Investments SICAV ( “The Fund”, “our”, “we”, or “us”).

2 Where we refer to “you”, this refers the following individuals or individuals related to certain counterparties, including but not limited to: 

• Website users, including individuals that email or contact us.

3 This Privacy Notice describes how we collect and process your personal data and it explains your rights. Personal data is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual. Processing includes all actions that can be performed on personal data such as collecting, organizing, storing, using, disclosing or otherwise making available, restricting, or destroying.

What information do we have about you?

4 We primarily obtain your personal information directly from you, including data about your usage of the website services and actions. Some information may be inferred from the information you provide or arise in the context of managing our relationships with you. Additionally, we may receive personal information about you from third parties such as third-party data providers, and from publicly available sources.

5 The nature of the personal data we collect depends on your relationship with us. For example, when you are visiting our website, we will process information about the webpages you view.

6 We may process the following personal data about you: If you are a Website user:

• Basic personal data such as name, job title, and business name.
• Contact information such as email address, postal address, and telephone number.
• Online electronic information such as cookies information (please see our Cookies Notice), IP address, engagement statistics, usage analytics, IT traffic and action traffic (including content accessed, shared, or downloaded).
• Information you provide when you fill in forms, or register to receive information from The Fund, subject to your consent or any other requirements under applicable laws.
• Information related to interactions with us (including by email, phone or other forms of electronic communication) to the extent permitted or required by applicable law.

7 Generally, special categories of personal data are not purposely processed by us, however in limited cases some special personal data may be implied or obtained, for example, from information you provide in support of a disability. Any special category personal data we receive is processed in accordance with applicable law.

How do we process your personal information and why is this justified?

8 We process your personal data for a specific purpose and only process the personal data, which is relevant to achieve that purpose. In particular, we process your personal data to:

• Manage our relationship with you;
• Communicate with you (including sending promotional or informational communications);
• Provide, develop, administer, support and improve our services, including our website;
• Take steps to protect the security, accuracy, and confidentiality of data and information held by us, and secure our IT systems, architecture, and networks including to detect and prevent cybersecurity and similar threats;
• Manage our operations and business;
• Enhance our knowledge of markets in general and analyze market data;
• Enter into pre-contractual discussions with you, and assess the services and suitability of potential vendors and service providers;
• Organize and hold online meetings, calls, and video conferences;
• Record audio or video of our interactions where required by applicable law and regulations (including financial regulations), or where permitted during our online events, meetings, or presentations;
• Preserve our economic interests including by protecting ourselves against, detecting, and preventing unlawful activity;
• Ensure our compliance with applicable legal and regulatory obligations and industry standards (e.g., complying with our policies and legal requirements);
• Preserve our legal interests (e.g., managing mergers and acquisitions, enforcing or defending our legal rights); and
• Any other purposes imposed by applicable law and governmental authorities,

9 We will process your personal data when we have a proper legal basis, such as:

• When it is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms. Please note that, when processing your personal data on this basis, we always seek to maintain a balance between our legitimate interests and your privacy. Examples of ‘legitimate interests’ are data processing activities performed:
  • to design, implement, and continuously improve efficient organizational processes (e.g., we may opt to use certain platforms or tools offered by suppliers to process data and enhance operational efficiencies, we may test our existing technology and security platforms to identify areas for improvement);
  • to benefit from cost-effective services (e.g., we may opt to use certain platforms offered by suppliers or service providers to process data);
  • to market and offer our company, products, and services;
  • to manage our relationship with you (e.g., to keep our records updated and to understand how users use the services);  to investigate allegations of or prevent fraud or criminal activity, compliance breaches, and misuses of our products, services, or our IT systems, architecture, and networks;
  • to sell any part of our business or its assets or to enable the acquisition of all or part of our business or assets by a third party; and
  • to meet our corporate and social responsibility objectives.
• To comply with our legal or regulatory obligations. For example, this might include in relation to: o adhering and monitoring adherence, as applicable, to international marketing laws or laws governing electronic communications, and financial services and financial supervisory regulations and rules; o complying with judicial or administrative orders as may be applicable to you/the entity related to you.
• To take pre-contractual steps; o to comply with our legal or regulatory obligations. For example, adhering and monitoring adherence to international marketing laws, laws relating to electronic communications, financial services and financial supervisory regulations and rules, and complying with judicial or administrative orders as may be applicable to you/the entity related to you.
• we have obtained your prior consent; or
• we are otherwise permitted or required by law to do so.

10 You are under no obligation to provide us with personal data. However, if you fail to provide personal data when requested and where such personal data is necessary for us, for example, to provide you with services, you may be prevented from using the services. We will notify you if this is the case at the time.

Who has access to your personal data and to whom are they transferred?

11 We will never sell your personal data.

12 In the course of our activities and for the same purposes as those listed in this Privacy Notice, your personal data may be accessed by or transferred to the following categories of recipients to achieve such purposes:

• our personnel;
• technology service providers, including cloud and database providers, and related consultants;
• any third parties to whom we assign our rights and obligations;
• our professional advisors and external lawyers; and
• our banks, lenders, and external auditors where lawfully required.  

Such recipients are obligated to protect the confidentiality and security of your personal data..

13 In limited circumstances, your personal data may be accessed by or transferred to law enforcement, regulatory bodies, or judicial authorities. This will occur only when legally required.

14 Your personal data may be processed by The Fund in a different country than where you are located. Your personal data may be transferred by Partners Group to the EEA, to the countries where Partners Group has an office, or to any country in the world where Partners Group’s service

providers are located, including for example the US. The data protection law in such other country may not give you as much protection as the data protection law in the country where you are located.

15 We ensure that any transfer is made in accordance with applicable data privacy law. For example, for transfers to a country deemed by a privacy authority to not offer the same level of protection, we ensure that the transfers are governed by appropriate safeguards, such as the European Commission Standard Contractual Clauses.

16 You may request additional information in relation to such cross-border transfers and obtain a copy of the adequate safeguard put in place by The Fund as described in the section titled Who can I contact if I have any questions or concerns?

How do we protect your personal data?

17 We implement technical and organizational measures to provide an appropriate level of security and confidentiality to your personal data. These measures consider the state of the art of the technology; the costs of its implementation; the nature of the data; and the risk of processing.

18 The purpose of these measures is to protect your personal data against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access, and against other unlawful forms of processing.

19 While we take reasonable care to implement such measures, remember that the internet is inherently unsafe, and we cannot guarantee the security of your personal data when transmitted over the internet or email.

How long do we store your personal data?

20 We will retain your personal data for as long as necessary to fulfil the purpose for which it was collected, to comply with legal or regulatory requirements, or for the establishment or defense of legal claims.

21 Where it is not possible to remove your personal data from our systems (for example, because your personal data has been stored in backup archives), we will securely store your personal data and isolate it from any further processing until deletion is possible.

What are your rights and how can you exercise them?

22 We recognize that you may have rights with regard to our processing of your personal data. While the nature and extent of these rights will differ from location to location, we have processes in place to respond in a timely manner to any valid request. Your rights may include:

• the right to access the personal data about you that we process;
• the right to request the correction of personal data that you believe is incorrect, obsolete, or incomplete;
• the right to request the erasure of your personal data;
• the right to restrict the use of your personal data to specific categories of processing;
• if your personal data is processed based on your consent, you have the right to withdraw your consent at any time (please note that if you withdraw your consent, processing based on your consent that took place before your withdrawal will remain lawful);
• the right to object, in whole or in part, to the processing of your personal data; and
• the right to request that the personal data you provided us be returned to you or transferred to the person or entity of your choice in a structured, commonly used and machine-readable format without hindrance from us.

23 You may exercise your rights at any time by using the details in the section Who can I contact if I have any questions or concerns? To the extent permitted by applicable law or regulation we reserve the right to charge an appropriate fee in connection with you exercising your rights.

24 We may need to request specific information from you to help us confirm your identity and ensure your right to access to the personal data requested, or to exercise any of your other rights. This is to ensure that personal data is not disclosed to any person who does not have authority to receive it. We may also request further information in relation to your request to help us to locate the personal data processed in relation to you, including, for example, the nature and location of your relationship with us.

Who can I contact if I have any questions or concerns?

25 This website is operated on behalf of The Fund by Partners Group AG, Zugerstrasse 57, 6341 Baar, Switzerland.

26 If you have any questions about how your personal data is processed, or if you want to exercise the above rights, you may contact Partners Group’s Data Protection Officer by email at DPO@partnersgroup.com.

27 You also have the right to complain to the competent data protection authority in relation to the processing of your personal data.

How will you be informed of the changes to our Privacy Notice?

28 We may modify or amend this Privacy Notice from time to time and you are advised to visit our website regularly to check for any amendments. This Privacy Notice has an effective date as shown at the end of the document.

Version November 2023