Privacy Policy

OUR COMMITMENT TO PRIVACY

Your privacy is important to BayPine LP and its affiliates (together, “BayPine,” “our,” “us” or “we”).

This Website Privacy Policy (this “Privacy Policy”) describes how we gather and use personal data, personally identifiable information and personal information (referred to herein as “personal information”):

  • from and about visitors of this website (the “Website”) or our other digital platforms (e.g., investor portals);
  • when you receive communications from BayPine or communicate or interact with us offline and online (including via phone, direct messaging platforms (including SMS), email correspondence or “Contact” links and in-person meetings and events);
  • when you apply for a job with us via our Website;
  • from and about representatives or business contacts of our vendors, suppliers and other business partners;
  • through other data collection points as described in this Privacy Policy; and
  • where we otherwise state that our processing of personal information is subject to this Privacy Policy.

Please read this Privacy Policy carefully. If you do not agree with any of the information contained herein, please do not access or otherwise use this Website.

By entering and using this Website, you acknowledge you have read and understood the information provided or referred to in this Privacy Policy, and you accept, and agree to be bound by, our Terms of Use. If you do not agree to our use of your personal information in accordance with this Privacy Policy, please do not access or use this Website.

If you are a resident of California, you should also refer to our California Website Privacy Policy. If you are located in the United Kingdom (“UK”), the European Union (“EU”), the European Economic Area (the “EEA”), or Switzerland, or the processing of your personal information would otherwise be subject to applicable laws and regulations relating to privacy, protection or processing of personal information in the EEA, EU, UK or Switzerland, including the General Data Protection Regulation (Regulation (EU) 2016/679) (“EU GDPR”), the UK’s equivalent of the EU GDPR and the Swiss Federal Act on Data Protection (collectively, the “EEA-UK Data Protection Laws”), you should also refer to our EEA-UK Website Privacy Notice.

THE PERSONAL INFORMATION WE COLLECT

For the purposes described in this Privacy Policy, the types of personal information we collect about you (and which we have otherwise collected in the last twelve (12) months), depends on the nature of your interaction with us, and includes the following:

  • Your basic information: such as your name, prefix/title, gender, age and/or date of birth, job title and/or position.
  • Contact information: such as personal and work physical address(es), telephone number(s) and/or email address(es).
  • Information we obtain by automated means: such as information about your computer / device and IP address, content and traffic data. We may also collect personal information about you through automated technology when you access and use our Website, such as cookies and similar technology (please see the “COOKIES” section below for information about how we use such technologies).
  • Information obtained through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications, and written correspondence such as email, direct messaging platforms (including SMS), etc.
  • Job applicant information: such as information that you may provide to us in connection with a job application, including CV information and identification documentation.
  • Information obtained in the context of a corporate transaction or potential investment: such as your name, title, email address, postal address, job title, job location, hire dates, telephone number, passport or other government-issued identification, financial information and other job-related and benefits information.
  • Other information: such as background information as made available by third parties or obtained through publicly available sources.

Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.

HOW WE OBTAIN YOUR PERSONAL INFORMATION

We may collect and maintain your personal information from the following sources:

  • Information provided by you in person or through communications with us, such as information obtained through written correspondence, including when you provide it to us in online or offline correspondence via physical mail, email, direct messaging platforms (including SMS), telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications.
  • Information captured on our Website or our other digital platforms, including registration and account information, information provided through online forms, or via any “Contact”, “Connect with Us” or similar pages.
  • Information provided by third parties or as available from publicly available sources, such as a CV sent to us by a recruiting firm, background information from a background check provider, personal information we viewed on social media (e.g., LinkedIn) or information obtained from publicly available lists of individuals subject to sanctions or trade restrictions. If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal information from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
  • Information such as your IP address and other online identifiers that are collected through automated technology when you access and use our Website, such as cookies and similar technology.
  • Information that are collected in the context of a corporate transaction or potential investment that we are pursuing or are party to.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

We will use the personal information we collect for one or more of the following purposes:

Purpose

Legal Basis

(for the purposes of EEA-UK Data Protection Laws, if applicable)

To conduct business with you or to provide you with the services or information you have requested, including responding to your inquiries and requests and providing you with support.

Contractual necessity; and/or our legitimate interest in operating our business and providing investment services.

To communicate with you, and to operate, schedule and facilitate meetings (in-person and online), and to administer your participation in any of our events.

Our legitimate interest in operating our business and providing investment services; and/or consent.

To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a business partner or supplier.

Our legitimate interest in operating our business and providing investment services; contractual necessity; legal requirement; and/or consent.

To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our Website and other platforms (including investor portals, products and services, databases, technology assets) or our business, and other malicious, or unlawful activity.

Legal requirement; and/or our legitimate interest in operating our business and Website.

To conduct conflicts checks.

Legal requirement.

To process and administer details associated with you, and to offer and improve our services.

Our legitimate interest in operating our business.

Complying with our legal obligations and corporate governance practices, which may require recording, archiving or monitoring telephone calls or other communications (such as direct messages (including SMS), emails, etc.) with you.

Legal requirement; our legitimate interest in operating our business.

Litigation management and conducting internal audits and investigations.

Legal requirement; and/or our legitimate interest in operating our business.

To keep a record of and manage your relationship with us.

Our legitimate interest in operating our business and providing services; and/or legal requirement.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

Our legitimate interest in operating our business; and/or legal requirement.

Corporate transaction and investment reporting.

Legal requirement; and/or our legitimate interest in operating our business.

To administer and ensure the performance of our business, this Website (including our other platforms and IT systems), and to ensure compliance with our Terms of Use

Consent or our legitimate interest in operating our business where we have an existing relationship with you.

To make suggestions and recommendations to you (including to provide you with updates or other information) about our business and services that may be of interest to you, including in relation to services that are similar to those services we currently provide, or previously provided, to you.

Our legitimate interest in operating our business.

For any other purpose that has been notified in writing.

As identified in the relevant notice or where the data subject has given consent to the processing of their personal information for the specific purpose.

If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, failure to provide this information means that we may not be able to conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.

[You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails or direct messages (such as SMS) by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails or such other method as may be communicated to you from time to time. You may also request that we stop sending you marketing communications by contacting us at 1.833.463.0211 or emailing us at info@baypine.com at any time.

DISCLOSURE OF PERSONAL INFORMATION

Your personal information may be disclosed to and processed by our affiliates and agents and certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including professional advisors, CEOs and CEOs-in-Training, recruitment firms, consultants and data hosting providers, and in some instances, placement agents and other fund administrators, as well as regulators, law enforcement and other government bodies. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. When we disclose your personal information, we will only do so to the extent such disclosure complies with applicable data protection laws.

We may also disclose personal information for the purposes described in this Privacy Policy and as required by law or regulation, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment, acquisition, joint venture, bankruptcy or similar proceeding, we may disclose your personal information to the new owner of the relevant business and their advisors.

The Website may contain links to other websites which are not hosted, affiliated or operated by us. These websites may use automated means to collect information regarding your use of the websites. Your use of such websites is subject to the privacy policies or notices of the provider’s website.

SECURITY AND RETENTION

The security of your personal information is important to us. We adopt and employ robust and appropriate security measures to protect any personal information you provide through the data collection points set out above from unauthorized access or use. You should be aware, however, that absolute security does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your information.

Although we make an effort to protect your personal information, we cannot guarantee the security of any information or data transmitted to or through the internet or our Website; any transmission of information or data by you to or through the internet, including, this Website is at your sole risk.

We have put in place procedures to deal with any suspected or actual personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We review the personal information we hold periodically and delete it securely. We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law (which may include information we are required to retain for archival purposes such as communication (including direct messages, such as SMS)). We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact us at 1.833.463.0211 [or email us at info@baypine.com].

CAPACITY

You represent to BayPine that you have the authority to visit this Website according to the Terms of Use. This Website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this Website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

COOKIES

Information regarding how you access this Website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve Website performance and for our business purposes. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.

You may access any personally identifiable information we have about you by contacting us at 1.833.463.0211 or emailing us at info@baypine.com.

NOTIFICATION OF CHANGES

We reserve the right to amend this Privacy Policy from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Policy. Accordingly, users are strongly encouraged to review this Privacy Policy regularly. If we decide to change this Privacy Policy, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the version of this Privacy Policy under which the information was collected. Your continued access or use of this Website following the posting of changes to this Privacy Policy constitutes your acceptance of, and agreement to be bound by, such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Policy, please stop accessing this Website. Please check this page frequently and review any changes to this Privacy Policy carefully so you are aware of any changes, as they are binding on you.

MISCELLANEOUS

The provisions in our Terms of Use are hereby incorporated by reference.

CALIFORNIA WEBSITE PRIVACY POLICY

This California Website Privacy Policy supplements the Website Privacy Policy with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Policy. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.

WHAT DOES THIS WEBSITE PRIVACY POLICY APPLY TO?

This Website Privacy Policy applies solely to your interactions with us through our Website (as defined below). If you provide personal information to use through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

We collect limited types of personal information through our Website, as well as through other electronic communications (e.g., emails), as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we collect from individuals on this Website may include the following:

Category

Examples

Collected

A. Identifiers

Name, contact details and address (including physical address, email address, phone number (for voice and SMS) and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number).

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information).

YES

C. Protected classification characteristics under California or federal law

Date of birth, citizenship and birthplace.

NO

D. Commercial information

Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s).

NO

E. Biometric information

Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information.

NO

F. Internet or other similar network activity

Use of our Website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries

YES

G. Geolocation data

Physical location or movements.

NO

H. Sensory data

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

L. Sensitive Personal Information (see further information on use of sensitive personal information below)

Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation.

YES, as to the following types of information: social security, driver’s license, state identification card, or passport numbers; account log-in, financial account in combination with any required security or access code password; or credentials allowing access to an account only.

We do not collect or use sensitive personal information other than:

  • To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
  • As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
  • As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
  • For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
  • To perform services on behalf of our business; and
  • To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

HOW DO WE OBTAIN YOUR PERSONAL INFORMATION?

In connection with forming and operating our Website, we may collect and maintain your nonpublic personal information from the following sources:

  • Information from your communications with us in connection with this Website, including any update notices provided by you.
  • Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We will use your personal information for one or more of the following business purposes:

  • To perform services for you.
  • To improve our Website and the products and services that we offer and notify you about changes to our products and services.
  • To communicate with you, including responding to requests for information submitted by you through our Website.
    - The number messages (voice, SMS & email) you receive will vary depending on how you use our services and whether you take steps to generate more messages from us (such as by sending a HELP request).
  • To keep a record of your relationship with us.
  • Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
  • To audit and verify the quality and effectiveness of our services and compliance.
  • To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
  • To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.

WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

We do not share mobile opt-in data with third parties, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have disclosed each of the categories of personal information collected in connection with this Website with affiliates and service providers as set forth above in “WHAT INFORMATION DO WE COLLECT ABOUT YOU?” We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Personal Information Category

Category of Third-Party Recipients

A. Identifiers

Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents.

C. Protected classification characteristics under California or federal law

N/A

D. Commercial information

N/A

E. Biometric information

N/A

F. Internet or other similar network activity

Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

G. Geolocation data

N/A

H. Sensory data

N/A

I. Professional or employment-related information

Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

K. Inferences drawn from other personal information

N/A

L. Sensitive Personal Information

Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents.

We may also disclose your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.

YOUR RIGHTS UNDER THE CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:

  • the categories of personal information we collected about you;
  • the categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting such personal information;
  • the categories of third parties to whom we disclose the personal information;
  • the specific pieces of personal information we have collected about you; and
  • whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

Correction Rights: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following toll-free number: 1.833.463.0211.

Email us at the following email address: info@baypine.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity.

Please contact us at the email address above with any questions about this California Website Privacy Policy.

EEA-UK WEBSITE PRIVACY NOTICE

GENERAL

This EEA-UK Website Privacy Notice supplements the Website Privacy Notice of BayPine above with respect to our use of personal information to the extent that EEA-UK Data Protection Laws (as defined in the general Privacy Notice) apply to our processing of your personal information. If there is any conflict between this EEA-UK Website Privacy Notice and the Website Privacy Notice above, this EEA-UK Website Privacy Notice shall apply. Please read this EEA-UK Website Privacy Notice carefully.

For the purposes of EEA-UK Data Protection Laws, BayPine will be a controller of any personal information collected or processed by us pursuant to this EEA-UK Website Privacy Notice. In simple terms, this means that we: (i) “control” the personal information that we collect from you or other sources provide, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal information. If you have any questions regarding our use of your personal information, or this EEA-UK Website Privacy Notice, please contact us at 1.833.463.0211[ or email us at info@baypine.com].

You do not need to take any action as a result of this EEA-UK Website Privacy Notice, but you do have certain rights as described below in the section headed “YOUR RIGHTS.

ANY ADDITIONAL PERSONAL INFORMATION WE MAY COLLECT

As discussed in “THE PERSONAL INFORMATION WE COLLECT” section of the general Privacy Notice, the types of personal information we collect depends on the nature of your interaction with us.

We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, etc.). Nor do we collect any information about criminal convictions and offences. However, there may be limited circumstances where we need to collect this type of personal information (e.g., due to a legal requirement or obligation or in order to perform a contract with you or in our legitimate interest as part of a job application). We will make you aware of this at the time we collect your personal information, and the possible consequences of you failing to provide this personal information. Failure to provide this information means that we cannot provide our services or products to 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 OBTAIN YOUR PERSONAL INFORMATION

We collect and process your personal information from you and other third parties and/or publicly available sources listed in “HOW WE OBTAIN YOUR PERSONAL INFORMATION” section of the general Privacy Notice above.

HOW WE USE YOUR PERSONAL INFORMATION

Further information about the purposes for which, and the legal bases under which, we process your personal information is included in the section of the general Privacy Policy headed “HOW WE USE THE PERSONAL INFORMATION WE COLLECT.”

We may process your personal information on more than one legal basis depending on the specific purpose for which we are using your personal information. 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 we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.

No solely automated decision-making, including profiling, is used when processing your personal information.

DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION

Information about who we may disclose your personal information to is included in “DISCLOSURE OF PERSONAL INFORMATIONsection of the general Privacy Notice.

To the extent your personal information is transferred to a Non-Equivalent Country (as defined below) and including the United States, such transfers will only be made in accordance with EEA-UK Data Protection Laws. For the purposes of this EEA-UK Privacy Notice, “Non-Equivalent Country” means a country or territory other than (i) a member state of the EEA; (ii) the UK; or (iii) a country or territory which has at the relevant time been decided by the European Commission or the Government of the UK, or the UK Information Commissioner (as applicable) in accordance with the applicable EEA-UK Data Protection Laws to ensure an adequate level of protection for personal information. For further information about the safeguards/derogations used, please contact 1.833.463.0211 [or email us at info@baypine.com].

YOUR RIGHTS

To the extent EEA-UK Data Protection Laws apply, you have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact us at 1.833.463.0211 [or email us at info@baypine.com].

  • Access: You have the right to ask for a copy of the personal information that we hold about you free of charge; however, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
  • Correction: You may notify us of changes to your personal information if it is inaccurate or if it needs to be updated.
  • Deletion: If you think that we should not be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
  • Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against applicable law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
  • Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
  • Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
  • Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.

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

CONTACT US

If you have any questions or concerns about this EEA-UK Website Privacy Notice, please contact us at 1.833.463.0211 [or email us at info@baypine.com].

COMPLAINTS

Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office – https://ico.org.uk/global/contact-us.