Date of most recent update: 24 May 2018

The data controller collecting the data described herein is 78.capital GmbH with registered office at Marmer Weg 1-3, 56470 Bad Marienberg Germany (hereafter “78.capital”). 78.capital is committed to respect privacy and this privacy statement details its approach thereon. By using the 78.capital website and submitting any personal data, you agree to the use by 78.capital of such data in accordance with this privacy statement.
If you have questions on the 78.capital privacy policy, please email us at compliance@78.capital.

Data collection

78.capital only collects personally identifiable information that is provided specifically and voluntarily by visitors of the 78.capital website. 78.capital receives limited identifiable information, such as first name, last name and email address from site visitors, typically to subscribe with the purpose of receiving more information from 78.capital including but not limited to press releases or 78.capital Insights. It is the policy of 78.capital to limit the information collected to only the minimum information required to complete a visitor’s request.

Visitors are also able to send email through the site. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. Because we use the 78.capital website as a recruiting tool, a visit to the 78.capital website may also result in the user sending a resume to an individual within 78.capital.

It is the intention of 78.capital not to seek any sensitive information through the 78.capital website unless legally required for recruiting purposes.

What is sensitive information? It includes a number of types of data relating to: race or ethnic origin; political opinions; religious or other similar beliefs; trade union membership; physical or mental health; sexual life or criminal record.

We recommend that you do not provide sensitive information of this nature. If you do wish to provide sensitive information for any reason, 78.capital accepts your explicit consent to use that information in the ways described in this privacy policy or as described at the point where you choose to disclose this information.

Use of Data

A user may choose to provide personal information in the following examples (non-exhaustive):
• Contact us to propose investment opportunities
• Subscribe to our press releases and/or 78.capital Insights
• Submit resumes or work history information
• Contact us for further information on 78.capital, its activities as listed private equity company or its portfolio
• Register for events
Information attained via the 78.capital website is used only for the intended purpose stated at the time that the information is collected. This data is not shared with other 78.capital entities for secondary or unrelated purposes, or shared with a third party, unless otherwise disclosed at the point of collection.

78.capital will make every practical effort to avoid excessive or irrelevant collection of data. If a visitor of the 78.capital website believes the site has collected excessive information, we encourage the visitor to contact us to raise any concerns.

Except where visitors explicitly choose to receive non-mandatory press releases, 78.capital Insights or other specific marketing materials, if any, 78.capital will not use personal data collected from the 78.capital website to facilitate unsolicited marketing activities.

Cookies and log file
Cookies may be used on some pages of the 78.capital website.

What are cookies? They are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the site so that a user does not need to re-enter it on subsequent visits to that area.

It is 78.capital’s policy to use cookies to make navigation of the 78.capital website easier for visitors and to facilitate efficient registration procedures. If you are concerned about cookies, most browsers permit individuals to decline cookies. In principle, a visitor may refuse a cookie and still fully navigate the 78.capital website. However, please note that some functionalities may be no longer usable after declining cookies.

In order to properly manage the 78.capital website, we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains and browser types. These statistics are reported in an aggregated manner to our webmasters to ensure that the 78.capital website presents the best web experience for visitors and is an effective information resource.

Third parties

We recognise that your information is valuable and we take all reasonable measures to protect your information while it is in our care. Your personal information may be transferred to third party service providers who process information on behalf of 78.capital, including providers of information technology, identity management, website hosting and management, data analysis, data back-up, security and storage services.

As a result, the possibility exists that your personal information is transferred outside the country where you are located. This includes countries outside the European Economic Area (EEA) and countries that do not have laws that provide specific protection for personal information. By submitting personal data to this site, the visitor is providing explicit consent to the transfer of such data for the fulfilment of their voluntary requests.

78.capital may disclose your personal information to law enforcement, regulatory, or other government agencies or to other third parties as required by, and in accordance with, applicable law or regulation.

Your personal information is not shared with any third party, for any secondary or unrelated purposes unless otherwise disclosed at the point of collection. If there is an instance where such information may be shared, the visitor will be asked for permission beforehand.

Third parties links

There are several places throughout 78.capital, which may link to other websites not operating under the privacy practices of 78.capital. When you link to other websites, the 78.capital privacy practices no longer apply. We encourage visitors to review each site’s privacy policy before disclosing any personally identifiable information.

Data retention

Contact information about visitors (such as information generated through registration for receiving information about 78.capital such as press releases, 78.capital Insights, etc.) will be kept as long as the information is required to completely service the contact request or until a user requests that 78.capital deletes that information.

Mailing list information and email are kept for only the period considered reasonable to facilitate the visitor’s requests. Resumes are disposed of when they are either no longer under consideration, or are considered outdated.

Choices

Visitors provide personally identifiable information provided to 78.capital through the 78.capital website, voluntarily. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions, on the appropriate website area or in communications to our visitors; or a visitor may contact compliance@78.capital.

Access, rectification, right to be forgotten & withdrawal of consent

Each visitor has the right of access to personal data they have submitted to 78.capital through the 78.capital website. 78.capital is committed to providing reasonable and practical access to visitors to allow them the opportunity to identify and correct any inaccuracies.

User updates of information should be handled by going back through the registration process. Inquiries about the accuracy of identifying information previously submitted to 78.capital through the 78.capital website, or requests to have outdated information removed, should be directed to compliance@78.capital.

When personally identifiable information is retained, 78.capital assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. 78.capital does not assume responsibility for verifying the ongoing accuracy of the content of personal information.

When practically possible, if 78.capital is informed that any personal data collected through a website is no longer accurate, 78.capital will make appropriate corrections based on the updated information provided by the authenticated visitor.

When requested and practical, 78.capital will delete identifying information from current operational systems.

Once a visitor has provided personal identifiable information to 78.capital in accordance with this privacy policy, he/she can withdraw his/her consentat any time by sending an email to compliance@78.capital. Such withdrawal does not affect the lawful character of past processing activities up until the moment of withdrawal.

Security

78.capital has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction. Only authorised 78.capital personnel is provided access to personally identifiable information and these employees have agreed to ensure confidentiality of this information.

Modification

78.capital reserves the right to modify or amend this 78.capital Privacy Policy at any time. The effective date will be displayed at the beginning of this statement.