Web terms

We collect yourpersonal data both online and offline. Most commonly, we receive your personaldata:

• From your direct interaction with us, for example when you visit ourwebsite or either when we are doing business together.• From your direct interaction with us, for example when you visit ourwebsite or either when we are doing business together.
  
• From public data sources like sanction lists, trade registers and LinkedIn,for instance where we need such personal data to verify your identity before wedo business with you.

Scipio Capital processes your personal data for the purposes as set out below. We also inform you of the legal ground on the basis of which we process your personal data (as required by the EUGeneral Data Protection Regulation). Where we rely on legitimate interest as a legal ground, we will always seek to maintain a balance between our legitimate business interests as described below and your privacy. If Scipio Capital processes personaldata for other purposes than as listed in this Privacy Notice, you will be informed thereof separately where required and consent will be sought if applicable local law so requires.

3.1. Assessment andacceptance of clients, conclusion and execution of agreements with clients, suppliers and business partners. This purpose includes processing of personal data that is necessary in connection with the assessment andacceptance of clients, suppliers and business partners, including confirmingand verifying the identity of relevant Business Contacts (this may involve theuse of a credit reference agency or other third parties) and conducting due diligence and screening against publicly available government and/or law enforcement agency sanctions lists (e.g. for compliance requirements). Thispurpose also includes the processing of personal data necessary to conclude and execute agreements with clients, suppliers and business partners, including required screening activities (e.g. for access to Scipio Capital’ premises orsystems), delivery of client services, and to record and financially settle delivered services and projects to and from Scipio Capital.

• The legal grounds for these processing activities are based on:
  • Capital is subject  
  •   The fact that the processing is necessary for the performance of a contract to which you are a party
  • compliance with a legal obligation to which Scipio.
  • our legitimate interest.

3.2. Relationshipmanagement and marketing. This purpose includes processing of personal data that is necessary for activities such as maintaining and promoting contact with every person taking part of this company through any via of communication.

• The legal grounds for these processing activities are:
  • your consent;
  • the fact that the processing is necessary for the performance of a contractt which you are a party;
  • our legitimate interest. 

3.3. Businessprocess execution, internal management and management reporting. This purpose includes processing of personal data that is necessary for the management of company assets, conducting audits and investigations, reviewing and monitoring compliance with internal policies and procedures, finance and accounting, implementing business controls, providing central processing facilities for efficiency purposes and managing mergers, acquisitions and divestitures. 

• The legal grounds for these processing activities are:
  • the fact that the processing is necessary for the performance of a contractto which you are a party;
  • compliance with a legal obligation to which Scipio Capital issubject; 
  • our legitimate interest. 

3.4. Health,safety, security and integrity purposes. This purpose includes the processing of personal data that is necessary for the protection of the rights,interests and assets of Scipio Capital and its employees, clients, suppliers and business partners and activities such as those involving health and safety. It also includes the authentication of client, supplier or business partner status and access rights.

• The legal grounds for these processing activities are:
  • the fact that the processing is necessary for the performance of a contractto which you are a party;
  • compliance with a legal obligation to which Scipio Capital is subject; or
  • our legitimate interest. 

3.5. Compliancewith the law. This purpose includes the processing of personal data that is necessary for the performance of a task carried out to comply with a legal obligation to which Scipio Capital is subject, including the disclosure of personal data to government institutions or supervisory authorities.

• The legal ground for these processing activities is compliance with a legal obligation to which Scipio Capital is subject. 

3.6. Protection ofthe vital interests of Business Contacts. This purpose includes the processing of personal data that is necessary to protect the vital interests of you as our Business Contact.

• The legal ground for these processing activities is protection of the vital interests of an individual.

In general, Scipio Capital will retain your personal data for the duration of your business relationship with Scipio Capital (e.g. during the time Scipio Capital services are delivered to your employer and you are our Business Contact) and for thetime it is necessary to keep your personal data after the end of the services. This period will depend on our purpose of use of your personal data. Examples are:

• Where your business contact details are included in our invoices, we will keep your personal data together with our invoices (usually 7 years based on tax legislation).
• Where your business contact details are included in our project plans, wewill retain your personal data in accordance with our project plan retention periods (usually 10 years depending on the project).
• Where we need your personal data for identification and screening purposes,we will keep your personal data for as long as we are required to keep proof of the screening based on local law.
• If you are one of our prospects, we will keep your contact details during the time that Scipio Capital sends you commercial messages you are interestedin (such as newsletters) and 24 months thereafter. 

Scipio Capital will deviate from these retention periods if Scipio Capital has a pressing interest to keep your personal data longer (e.g. in case of ongoing or expected litigation).