Windsor Heritage Capital Privacy Notice

‍Last Updated: October 26, 2023


This Privacy Notice explains how Windsor Heritage Capital Partners (including Windsor Heritage Capital Services LLC, Windsor Heritage Capital Partners LP,Windsor Heritage Capital Partners International LLP, Windsor Heritage Capital Capital Partners Management LP and Windsor Heritage Capital Capital Partners GP LLC) (together "Windsor Heritage Capital", "we", "us" or "our") collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with windsorheritagecapitals.com (the "Site") and other websites Windsor Heritage Capital owns and/or operates that link to this Privacy Notice or through other methods (e.g, e-mail, telephone, etc.), and the related content, platform, services, products, applications and other functionality offered on or through our services, including our investment banking services (collectively, the "Services").


Windsor Heritage Capital is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.

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I. What is Personal Information?


When we use the term "personal information" in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household.
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II. Our Collection & Use of Personal Information


We collect personal information in a variety of ways. For example, you may provide us your personal information when you subscribe to our mailing lists or other Windsor Heritage Capital communications, submit an application for an internship or employment at Windsor Heritage Capital or use some other feature of our Services.

We may link or combine your activities and information collected from you on our Site with information we receive from third parties, as well as information we collect automatically through tracking technologies (defined below). This allows us to provide you with a personalized experience regardless of how you interact with us.


Personal Information Collected from You
‍We may collect the following categories personal information submitted to us by individuals through the Services:

  • Business Contact Information, including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction and to communicate with you in accordance with your preferences.
  • Inquiry and Communications Information, including information provided in custom messages sent through the forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Services. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.

Personal Information Automatically Collected
As is true of many digital properties, we and any of our third-party providers may automatically collect certain information about you, your preferences, or your device when visiting or interacting with our Services, such as the list below and in the sub-sections here:

  • Log data, including internet protocol (IP) address, operating system, device type and version, browser type and version, browser ID, the URL entered, the referring page/campaign, date/time of visit, other user agent string data, the time spent on our Services, and/or any errors that may occur during the visit to our Services). Log data may overlap with the other categories of data below.
  • Analytics data, Including the electronic path you take to our Services, through our Services and when exiting our Services, UTM source, as well as your usage and activity on our Services, such as the time zone, activity information (first and last active date and time), usage history (flows created, campaigns scheduled, emails opened, total log-ins) as well as the pages, links, objects, products and benefits you view, click or otherwise interact with. We may also analyze the interaction between you and your customer using our Services.
  • Location data (such as general geographic location that we or any of our third-party providers may derive from your IP address).

We and our third-party providers may use (i) cookies or small data files that are stored on an individual's computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, "cookies") to automatically collect this personal information. We may also use this information to distinguish you from other users of our Services. This helps us monitor and analyze how you use and interact with our Services. It also helps us and our third party partners to determine products and services that may be of interest to you. For more information about these practices and your choices regarding cookies, please see the Control Over Your Information section of this Privacy Notice.

‍Personal Information from Third Parties
‍We may also obtain personal information from third parties; which we may combine with personal information we collect either automatically or directly from an you and/or others. We may receive the same categories of personal information as described above from the following third parties:

  • Windsor Heritage Capital Entities: Windsor Heritage Capital entities may receive personal information such as the information described in the sections above headed Personal Information Collected from You and Personal Information Automatically Collected from other companies and brands owned or controlled by Windsor Heritage Capital. and other companies owned by or under common ownership with Windsor Heritage Capital.
  • Your Employer / Company: If you interact with our Services through your employer or company, we may receive your information from your employer or company, including another representative of your employer or company. We use this information to operate, maintain, and provide to you the features and functionality of the Services.
  • Service Providers: Our service providers collect personal information on our behalf and often share some or all of this information with us. The information may include business contact information, information about your communications and related activities, and information about the use of our Services. We may use this information to administer and facilitate our Services.
  • Business Partners: We may receive your information from our business partners. We may use this information to administer and facilitate our Services.
  • Other Sources: We may also collect personal information about individuals that we do not otherwise have from, for example, publicly available sources, third-party data providers, or through transactions such as mergers and acquisitions, private placements, underwriting or investing. We use this information to operate, maintain, and provide you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you, and otherwise provide our Services.

Through the provision of our Services, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Windsor Heritage Capital commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Windsor Heritage Capital satisfies the requirements under applicable law.

‍Additional Uses of Personal Information
‍We may use personal information we collect to:

  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the Services you have requested;
  • Manage our organization and its day-to-day operations;
  • Verify your identity and entitlement to products or Services;
  • Register you for and provide you access to events and webcasts;
  • Communicate with individuals, including via email, text message, Teams, WhatsApp and/or telephone calls;
  • Administer, improve and personalize our Services, including by recognizing an individual and remembering the individual's information when the individual returns to our Services;
  • Conduct research and analytics on our customer and/or user base and/or our Services;
  • Improve and customize our Services to address the needs and interests of our user base and/or other individuals we interact with;
  • Test, enhance, update and monitor the Services and/or to diagnose and/or fix technology problems;
  • Help maintain the safety, security and integrity of our Site and Services;
  • To enforce our contractual rights, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
  • Comply with contractual and legal obligations or requirements, such as know-your-customer and anti-money laundering requirements or respond to any legal process, subpoena or court order;
  • To comply with our regulatory obligations, including responding to the requests of any regulator;
  • To fulfill any other purpose for which you provide personal information;
  • For any other lawful purpose; and
  • For any other purpose that you consent to.

Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
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III. Our Disclosure of Personal Information


We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:

  • Entities within the Windsor Heritage Capital group of companies: We may share personal information with other companies owned or controlled by Windsor Heritage Capital, and other companies owned by or under common ownership as Windsor Heritage Capital, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
  • Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
  • Consultants and/or Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as investment advisers and software providers. For example, we may disclose personal information to Inter Invest S.A. for certain Services that are regulated in the European Union;
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets or equity. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors, regulators and law enforcement:

    - in connection with the establishment, exercise, or defense of legal claims;
    - to comply with laws or to respond to requests or legal process;
    - to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
    - to detect, suppress, or prevent fraud;
    - to protect the health and safety of us and others; or
    - as otherwise required by applicable law.
  • With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with the individual's consent or direction. For example, with an individual's consent or direction, we may post the individual's testimonial on our Site or in Service-related publications.

IV. Control Over Your Information


You may control your information in the following ways:

  • Device and Browser Settings. You may control the Services' access to your device and browser information through your "Settings" app on the applicable device or browser.
  • Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the "unsubscribe" link provided in such communications. You may not opt-out of service-related communications (e.g., transactional communications, changes/updates to features of the Services, technical and security notices).
  • Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, please contact us. We may not be able to modify or delete your information in all circumstances.
  • Cookies: For information about our and our third-party partners' use of cookies and related technologies to collect information automatically, and any choices you may have in relation to cookies, please see the Information We Collect Automatically section above.

V. Data Retention


We generally store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information until deletion or deidentification is possible.
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VI. Children's Personal Information


Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, the individual should not use our Services or otherwise provide us with any personal information either directly or by other means. Subject to our regulatory obligations, including responding to the requests of any regulator, i a child under the age of 16 has provided personal information to us, we encourage the child's parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information (unless otherwise required by our regulatory obligations).
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VII. Links to Third-party Websites or Services


Our Services may include links to third-party websites, plug-ins,applications and services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites, plug-ins, applications and services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

VIII. Updates to This Privacy Notice


We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. All changes shall be effective from the date of publication unless otherwise provided.
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IX. Contact Us


If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to [email protected].
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